L-18-271, License Amendment Request - Proposed Post-Shutdown Emergency Plan

License Amendment Request - Proposed Post-Shutdown Emergency Plan

ML19036A524
Person / Time
Site:	Davis Besse
Issue date:	02/05/2019
From:	Huey D FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-18-271
Download: ML19036A524 (515)

Text

{{#Wiki_filter:FENOC n*uUrhtWOWV 5il1 North Sfafe Route 2 Oak Harbn Ohio 43449 Douglas B. Huey 419-321{,409 Director - Sife Performance I mprovement Fax:419-321-7ffi2 February 5, 2019 L-1 8-271 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 License Amendment Request - Prooosed Post-Shutdown Emeroencv Plan ln accordanoe with 10 CFR 50.90, 'Application for amendment of license or construction permit,' FirstEnergy Nuclear Operating Company (FENOC) requests an amendment to the Renewed Facility Operating License No. NPF-3 for Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). The proposed amendment would revise the DBNPS Emergency Plan for the post-shutdown and permanenty defueled condition. The proposed changes are being submitted to the Nuclear Regulatory Commission (NRC) for approval, prior to implementation, pursuant to 10 CFR 50.54(qX4). By letter dated April 25, 2018 (Accession No. ML18115A007), FENOC certified to the NRC, pursuantto 10 CFR 50.82(aXl)(i) and 10 CFR 50.4(bXB), that poweroperation wil! cease at DBNPS by May 31,2020. Once the certifications of permanent cessation of power operation and of permanent removal of fuel from the reactor vessel is docketed for DBNPS, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the license wil! no longer authorize reactor operation or emplacement or retention of fuel into the reactor vessel. The proposed changes to the DBNPS Emergency Plan would revise the on-shift and the augmented Emergency Response Organization (ERO) stafftng in support of the post-shutdown and permanently defueled condition of DBNPS. ln addition to the proposed changes associated with the shutdown and defueled condition, other minor changes to the emergency plan are proposed. FENOC has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E and concludes that the standards and requirements will continue to be met.

Davis-Besse Nuclear Power Station, Unit No. 1 L-1 8-271 Page2 The proposed changes to the DBNPS Emergency Plan are @mmensurate with the reduced spectrum of credible accidents in the post-shutdown and permanently defueled condition. ln order to assist in the transition from an operating facility to a permanently defueled facility, the changes are required to properly reflect the conditions of the facility while continuing to preserve the DBNPS Deoommissioning Trust Fund and the effec-tiveness of the DBNPS Emergency Plan. The description and evaluation of the proposed changes to DBNPS Emergency Plan are contained in Enclosure A. Attachment 5 of the enclosure contains a new regulatory commitment. Between November 26 and 29,2018, FENOC discussed the proposed changes to the DBNPS Emergency Plan with State of Ohio, Ottawa County, and Lucas County officials. Enclosure B provides copies of letters from the aforementioned organizations indicating that they understand the proposed changes and are satisfied that the proposed changes do not impac't their respective radiologica! emergency preparedness plans. FENOC requests review and approval of the proposed Iicense amendment by January 31,2O2O, and a 90day implementation period from the effective date of the amendment. FENOC requests that the approved amendment become effective following the docketing of the certifications required by 10 CFR 50.82(aXl) that DBNPS has been permanently defueled. lf there are any questions, or if additional information is required, please contact Mr. Thomas Lentz, Manager, FENOC Nuclear Licensing and Regulatory Affairs, at (330) 315-6810. or perjury that the foresoins is true and conect. Executed on tffilX;uTlg. l;ifly Sincerely Douglas B. Huey

Davis-Besse Nuclear Power Station, Unit No. 1 L-l8-271 Page 3

Enclosure:

A. Evaluation of a Request for Licensing Action B. State and County Reviews CG: NRC Region lll Administrator NRC Resident lnspector NRR Project Manager Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison) Utility Radiological Safety Board

Enclosure A L-18-271 Evaluation of a Request for Licensing Action (509 Pages Follow)

Evaluation of a Request for Licensing Action Page 1 of51

Subject:

Request to Revise the Davis-Besse Nuclear Power Station Emergency Plan 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Description of the Proposed Changes 2.2 Proposed On-Shift Staffing Changes 2.3 Additional Staffing Considerations 2.4 Proposed Augmented Emergency Response Organization Changes 2.5 Other Changes 3.0 REASON FOR PROPOSED CHANGES

4.0 TECHNICAL EVALUATION

4.1 On-Shift and ERO Staffing Regulations and Guidance 4.2 D BN Ps-Specific Backg round 4.3 Accident Analysis 4.4 Functional Area Technica! Evaluation 4.5 Emergency Response Organization Changes - Emergency Response Facility Evaluation 4.6 Assessment of Proposed Staffing Changes on Offsite Response Organization I nterfaces 47 Validation and Training 48 Conclusion

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration Analysis 5.4 Conclusions 6.0 ENVIRONMENTALCONSIDERATION 7,0 REFERENCES ATTACHMENTS

1. Tabular Summary of Proposed Changes to the DBNPS Emergency Plan, Revision 33

2. Proposed Revisions to the DBNPS Emergency Plan, Revision 33 (Marked-up Version)

3. Proposed Revisions to the DBNPS Emergency Plan, Revision 33 (Clean Version)

4. Emergency Response Organization Task Analysis

5. List of Regulatory Commitments

Page 2 of 51 1.0

SUMMARY

DESCRIPTION This evaluation supports a FirstEnergy Nuclear Operating Company (FENOC) request to amend Renewed Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station (DBNPS). The proposed amendment would revise the DBNPS Emergency Plan on-shift and augmented Emergency Response Organization (ERO) staffing to support the planned permanent cessation of power operations and permanent defueling of DBNPS. Specifically, the proposed changes in this license amendment request would eliminate on-shift ERO positions not needed for the safe storage of spent fuel in the spent fuel pool (SFP) during the initial decommissioning period and eliminate those augmented ERO positions not necessary to effectively respond to remaining credible accidents. The proposed changes to the on-shift and augmented ERO staffing are commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facility. The proposed amendment includes two regulatory commitments; the first is to have a chemistry technician available during fuel handling activities should a radiation monitor not be available to evaluate the need to enter an emergency action level (EAL) should facility conditions warrant, and second, to conduct a drill to confirm the ability of the augmented ERO to perform required functions. The commitments are described in Attachment 5. FENOC has evaluated the proposed changes in accordance with 10 CFR 50.54(q) and has determined the proposed changes are a reduction in effectiveness of the DBNPS Emergency Plan as defined in 50.54(q)(1Xiv). ln accordance with 10 CFR 50.54(qX4), changes to the emergency plan that reduce the effectiveness of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval; therefore, the proposed changes to the DBNPS Emergency Plan are hereby submitted to the NRC as a license amendment request in accordance with 10 CFR 50.90. 2,0 DETAILED DESCRIPTION 2.1 Description of Proposed Chanqes The on-shift and augmented ERO staffing is being revised to respond to the reduced spectrum of credible accidents for a permanently shutdown and defueled power reactor facility. Most of the accident scenarios postulated in the Updated Final Safety Analysis Report (UFSAR) will no longer be applicable with the reactor in the permanently shutdown and defueled condition. The Operations staff will no longer be required to implement emergency operating procedures and the scope of the applicable abnorma! response procedures that remain will be significantly reduced.

Page 3 of 51 provides a tabular summary of the proposed changes to the DBNPS Emergency Plan addressing the permanently shutdown and defueled condition. provides the revised DBNPS Emergency Plan with the proposed changes shown in a markup format. Attachment 3 provides a clean version of the revised DBNPS Emergency Plan. Attachment 4 contains an ERO task analysis of the augmented ERO positions proposed for elimination evaluating the transfer of tasks to remaining ERO positions in the permanently shutdown and defueled condition. contains a regulatory commitment to conduct a drill to confirm the ability of the augmented ERO to perform required functions. 2.2 Proposed On-Shift Staffinq Chanqes The current minimum required on-shift staff detailed in DBNPS Emergency Plan Table 5-1, "Manpower, Location, and Response Considerations for Emergencies," A, "Onshift Minimum Staffing Requirements," consists of: o One (1) Shift Manager (SRO) [Senior Reactor Operator] o One (1) Unit Supervisor (SRO) o One (1) Shift Engineer (STA) [Shift TechnicalAdvisor]

   . Two (2) Reactor Operators (ROs)
   . Six (6) Non-Licensed Operators (NLOs)
   . One (1) Radiation Protection Technician
   . One (1) Chemistry Technician
   . One (1) Security Shift Supervisor o  One (1) CAS Operator Following docketing of the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS Emergency Plan will be revised to eliminate the following on-shift positions:
   . One (1) Unit Supervisor (SRO) o  One (1) Shift Engineer (STA) o  Two (2) Reactor Operators (ROs)
   . Four (4) Non-Licensed Operators (NLOs)
   . One (1) Chemistry Technician The following proposed on-shift complement will be required to implement the DBNPS Emergency Plan in the permanently shutdown and defueled condition:
   . One (1) Shaft Manager [qualified as a Certified Fue! Handler (CFH)]

o Two (2) Non-Certified Operators (NCOs)

   . One (1) Radiation Protection Technician
   . One (1) Security Shift Supervisor
   . One (1) CAS Operator

Page 4 of 51 To support the reduction in on-shift staffing following docketing of the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS staffing levels were evaluated by reviewing 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 (Reference 1) and validating the conclusion of this amendment request, in part, by using the methodology in Nuclear Energy lnstitute (NEI) 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," (NEI 10-05) (Reference 2), considering the postulated accidents that will be applicable to DBNPS in the permanently shutdown and defueled condition. Section 4.5 contains a summary of the results of an analysis of the proposed post-shutdown on-shift staffing performed to address the permanent shutdown of DBNPS. The required DBNPS on-shift staff following permanent removal of fuel from the reactor vessel is commensurate with the need to safely store spent fuel in a manner that is protective of public health and safety. The required staffing is addressed in detail in Section 4.0. 2.3 AdditionalStaffinoConsiderations 2.3.1 Fire Brioade Staffin q Fire Brigade staffing is described in Section 4.4.7. The Fire Brigade complement will continue to consist of five (5) trained and qualified responders, including a Fire Brigade Captain and four (4) additionaltrained and qualified Fire Brigade Members in accordance with the Fire Hazards Analysis Report. 2.3.2 Position Titles Changes in position titles [Non-Certified Operator (NCO) and Certified Fuel Handler (CFH)] are consistent with changes proposed by a license amendment request submitted to the NRC on October 22,2018 that revises Technical Specifications Sections 1.1 "Definitions," and 5.0 "Administrative Controls" for a permanently defueled condition (Reference 3). The proposed changes would revise the minimum shift staffing requirements at DBNPS by replacing references to licensed and non-licensed operators with references to CFHs and NCOs. The NCO position is used to differentiate from the Shift Manager position. A CFH program was submitted to the NRC by letter dated August 15,2018 (Accession No. ML18227A019) (Reference 4). An individual qualified as a CFH will supervise and perform fuel handling operations when the DBNPS reactor is in the permanently shutdown and defueled condition. Shift Managers will be qualified as CFHs. The Shift Manager requires additional qualifications beyond the CFH training. Command and controlwill remain with the Shift Manager, regardless of location of the individual designated as the Shift Manager, until relieved by the Emergency Plant Manager or the Emergency Assistant Plant Manager. NCOs will perform duties typically associated with those performed by NLOs, such as manipulation and monitoring of plant equipment. NCOs will also be assigned to monitor indications and communications in the Control Room.

Page 5 of 51 The specific training requirements of the positions wil! be developed by the DBNPS Training Department and will be reviewed and approved by Operations management. The training program will be designed with an emphasis on systems and processes important to maintaining SFP cooling and monitoring, and controlling SFP parameters, such as SFP water level and temperature. Consequently, the positions will be trained on pertinent Control Room indications and controls that will be monitored and operated to maintain SFP cooling and SFP water level, in addition to monitoring plant radiologica! conditions. The training program wil! include training on applicable aspects of the DBNPS Emergency Plan-related duties. lndividuals will be trained and qualified consistent with 10 CFR 50.120, "Training and qualification of nuclear power plant personnel." Personnel assigned to fillthe NCO positions could include either currently licensed operators or current NLOs. With respect to the licensed operators being assigned as NCOs, much of the required training for the NCO position will already have been completed since the individuals have been trained and qualified as licensed operators to support power operations. With respect to the NLOs assigned as NCOs, they have been trained and qualified as NLOs to support power operations. Therefore, it is expected that these individuals will require additionaltraining related to Control Room operations when the DBNPS reactor is in the permanently shutdown and defueled condition. 2.3.3 Senior Site Manaqement ln addition to the above changes, in the DBNPS post-shutdown organization, the positions of Site Vice President and Director, Performance lmprovement will not exist. The General Plant Manager will assume the responsibilities assigned to the positions of Site Vice President and Director, Performance lmprovement in the DBNPS Emergency Plan. 2.4 Proposed Augmented Emerqencv Response Oroanization Chanqes Following docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS Emergency Plan will be revised to modify the augmented ERO commensurate with the reduced spectrum of credible accidents for the permanently shutdown and defueled reactor and the need to safely store spent fuel at the facility in a manner that is protective of public health and safety. The proposed changes to the DBNPS Emergency Plan would eliminate certain augmented ERO positions currently identified in Section 5.0 and Figure 5-2 of the DBNPS Emergency Plan, and in the Emergency Plan lmplementing Procedures (EPlPs) that describe the activation and operation of the Technical Support Center (TSC), Operations Support Center (OSC), Emergency Operations Facility (EOF), and Joint Information Center (JlC). The augmented ERO positions proposed for elimination are identified in Table 2.4-1 and Sections 4.4 and 4.5.

Page 6 of 51 Table 2.4-1 Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented Positions ERO Positionsl'2 Technical Support Center Emergency Plant Manager Emergency Plant Manager Emergency Assistant Plant Manaqer Emergency Assistant Plant Manager3 Recovery Advisor TSC Engineering Manager TSC Engineering Manager TSC Engineering Lead TSC Operations Lead TSC Engineers (Mechanical, Electrical, l&C, Mechanica!, Electrical, l&C, Operations - Operations) Available to respond on an as-needed basis as determined by the TSC Engineering Manager Core/Thermal Hydraulics Engineer TSC Computer Technician Severe Accident Management (SAM) Engineer Emergency RP Manager Emergency RP Manaqer Emergency Security Manager Emergency Security Manager OCA Security Supervisor OCA Security Supervisor Operations Support Center OSC Manager OSC Manager Assistant OSC Manager OSC Systems Engineersa OSC RP Coordinator OSC RP Coordinator OSC Communicator OSC Team Briefer/Debriefer and RP Briefer/Debriefer5 Rad Data Technician Rad Data Technician On-call Personnel (Electrical, l&C, On-call Personnel (Electrical, Mechanica! Mechanical Maintenance, RP, Chemistry) Maintenance, RP, Chemistry) - Reduced numbers6 Pool Personnel (Electrical, l&C, Mechanical Available to respond on an as-needed basis Maintenance, RP, Chemistry, Operations) Emergency Operations Facility Emergency Director Emergency Director Emergency Offsite Manager Emergency Offsite Manager Emergency Director Advisor EOF Operations Advisor Dose Assessment Coordinator Dose Assessment Coordinator RTL Coordinator RTL Coordinator

Page 7 of 51 Table 2.4-1 (Continued) Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented Positions ERO Positionsl'2 RMT Coordinator RMT Coordinator Emergency Operations Facility (continued) Dose Assessor (2) Dose Assessor (1) DBAB RMTs DBAB RMTs Field RMTs Field RMTs Emergency Facility Services ManagerT Emergency Planning Advisor Emergency Planning Advisor Log & Status Board Keepers State/County Communicator State/County Communicator Resource Coordinator (including Warehouse pool personnel) NRC Liaison Assembly Area Coordinator (including Maintenance Services personnel) Technical Liaison - EOF Communicator Technical Liaison - EOF Communicator Technical Liaisons (Ohio, Ottawa County, Technical Liaisons (Ohio, Ottawa County, Lucas Countv) Lucas County) Joint lnformation Genter Company Spokesperson Company Spokesperson JIC Manager JIC Manager Public Affairs Duty Officer Security Security JIC Writer News Statement Coordinator JIC Communicator Public Relations Communicator8 AudioA/isual Coordinator Technical Briefer Technical Briefer Public lnquiry Hotline Operator Public lnquiry Hotline Operator Media Assistant (2) Media Assistant (2) A dash C-) indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan. lnformation regarding the proposed elimination of each position is provide in Sections 4.4,4.5, and Attachment 4. 3 The Emergency Assistant Plant Manager reports to the Control Room. 4 Disciplines represented include primary systems, secondary systems, and electrical and controls. The OSC Team Briefer/Debriefer and RP Briefer/Debriefer are two separate positions. 6 Eliminates one (1) mechanical maintenance technician, one (1) electrical maintenance technician, two (2) instrumentation & control (l&C) technicians, one (1) chemistry technician, and two (2) RP technicians. 7 Position is located in the TSC, but the position reports to the Emergency Offsite Manager located in the EOF. 8 Position is located in the EOF, but position reports to JIC Manager located in the JlC.

Page I of 51 The intent of Table 2.4-1 is to compare the current augmented ERO positions against the proposed post-shutdown augmented ERO positions. As an example, the TSC Core/Thermal Hydraulics Engineer is a position that is proposed for elimination in the post-shutdown augmented ERO, because in a permanently shutdown and defueled condition the responsibilities associated with monitoring a reactor core are no longer needed. The proposed elimination of the listed augmented ERO positions are described in the following sections. identifies the current augmented ERO and contains an analysis of the augmented ERO positions proposed for elimination, evaluating the transfer of tasks to remaining ERO positions in the permanently shutdown and defueled condition. The analysis evaluates and dispositions each ERO task as being reassigned or eliminated, as appropriate. The Table provided in Attachment 4 contains columns with headings "lmplementing Actions" and "Task Assigned To?". These columns provide the details regarding the disposition of each task. Some of the duties are identified as being eliminated because they become unnecessary following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. Other duties are identified as eliminated because the duties are performed redundantly by other positions in the ERO and will continue to be performed by those positions in the post-shutdown augmented ERO. DBNPS will revise procedures consistent with the proposed changes presented in to align with the revised ERO task assignments. These procedures will be used to support training of the post-shutdown augmented ERO staff and during the conduct of drills to validate the staffing and assignment of tasks. 2.5 Other Chanqes Additionally, a number of administrative changes are being proposed to the DBNPS Emergency Plan that are not related to the on-shift and augmented ERO staffing changes proposed to support the planned permanent cessation of power operations and permanent defueling of DBNPS. These changes include, but are not limited to, changes that improve grammar and correct typographical errors. The changes are described in Attachment 1. These changes do not adversely impact the DBNPS Emergency Plan and are not evaluated further. 3.0 REASON FOR PROPOSED CHANGES The proposed changes reflect the pending permanent cessation of operation and permanent defueling of the DBNPS reactor, which is expected to occur by May 31,2020. After the reactor is shutdown, the fuel assemblies will be removed from the reactor vessel and placed into the SFP. After a suitable time period, the irradiated fuelwill be transferred from the SFP to the ISFSI with the irradiated fuel already stored there. The irradiated fuel will be stored at the ISFSI until the irradiated fuel is removed from site.

Page 9 of 51 Upon docketing of the certifications for permanent cessation of operations, 10 CFR 50.82(a)(1)(i), and permanent removal of fuelfrom the reactorvessel, 10 CFR 50.82(a)(1)(ii), pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license for DBNPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. The proposed revisions to the DBNPS Emergency Plan are commensurate with the reduction in hazards associated with the permanently defueled condition and will allow the facility staff to transition from that required for an operating facility to that required for a permanently defueled facility. The proposed changes are required to properly reflectthe conditions of the facility while continuing to preserve the DBNPS Decommissioning Trust Fund and the effectiveness of the DBNPS Emergency Plan. 4,O TECHNICAL EVALUATION An evaluation of the proposed changes to the DBNPS Emergency Plan on-shift and augmented ERO staffing that supports the planned permanent cessation of power operations and permanent defueling of DBNPS is contained in the following paragraphs 4.1 On-Shift and ERO Staffino Requlations and Guidance The onsite emergency plan planning standards in 10 CFR 50.47(b)(2) state, in part, that: On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initialfacility 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. NUREG-0654, Section ll.B, "Onsite Emergency Organization," provides guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section lV.A. The guidance describes the onsite emergency organization, including the staffing requirements contained in Table B-1. This table specifies a minimum of ten on-shift responders in four Major Functional Areas. lt also specifies seven on-shift response functions where the duties may be performed by shift personnel who are assigned other functions (that is, there are no dedicated responders to perform these functions). Table B-1 specifies two Major FunctionalAreas (that is, firefighting and site access control and accountability) which must be staffed on a site-specific basis. The on-shift staff must be able to cope with a spectrum of events until augmenting personnel arrive in accordance with the site's emergency plan and site-specific commitments. The augmenting responders assume managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnelto focus on their assigned functions.

Page 10 of 51 On November 23,2011, the NRC published a final rule in the Federal Register amending certain emergency preparedness requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 5). This final rule amended 10 CFR Part 50, Appendix E, Section lV.A, "Organization," to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions Specifically, Section !V.A.g states that licensees shall perform, "... a detailed analysis demonstrating that on-shift personne! assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan." Coincident with the rule change in 10 CFR Part 50, Appendix E, Section lV.A.9, the NRC issued lnterim Staff Guidance (lSG) NSIR/DPR-!SG-01, "lnterim Staff Guidance - Emergency Planning for Nuclear Power Plants" (ISG-O1) (Reference 6). The ISG provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI developed NEI 10-05 to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(qX5). 4.2 DBNPS-SpecificBacksround DBNPS Emergency Plan Table 5-1A, "Onshift Minimum Staffing Requirements," describes the minimum on-shift staffing utilized to support the emergency plan. Table 5-1A specifies the on-shift staffing for certain positions in the Major Functional Areas identified in Table B-1, "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies" of NUREG-0654, including: o Plant Operations and Assessment of OperationalAspects o Emergency Direction and Contro! o Notification and Communication

   . RadiologicalAssessment
   . Plant System Engineering, Repair and Mitigative Actions
   . ln-Plant Protective Actions
   . Fire Fighting o   First Aid and Rescue
   . Site Access Control and Accountability DBNPS Emergency Plan Table 5-1B, "Augmented Emergency Response Staffing Requirements," outlines the other key responders (augmented ERO) capable of responding within 30 minutes of an emergency declared during normal hours and within

Page 11 of51 60 minutes of an emergency declared during off-hours to support the on-shift organization. Table 5-1B also identifies the Emergency Response Facility (ERF) reporting locations for the augmenting ERO personne!. 4.2.1 On-Shift Staffino DBNPS Emergency Plan, Section 5.0, "Organizational Control of Emergencies," describes the key DBNPS ERO positions and associated responsibilities. The section outlines the on-shift staffing requirements, which provide initial emergency response actions and provisions for timely augmentation of on-shift personnel when required. The DBNPS ERO, including the normal on-shift organization is described in Section 5.1, "DBNPS Organization," and Section 5.3, "Onshift Emergency Response Organization." The normal watch organization is presented in Figure 5-1, "Onshift Emergency Organization," and functions 24 hours per day, 7 days per week. lf initiating conditions exist that result in the declaration of an emergency, the Shift Manager assumes the role of Emergency Director and is responsible for emergency direction and coordination. The normal operating organization assumes their pre-assigned emergency response roles. This is considered to be a short-term response organization that will be augmented within one hour after call-out of additional plant personnel. To address the required on-shift staff while DBNPS is operating, an on-shift staffing analysis was conducted in accordance with the guidance provided in NEI 10-05 satisfying the requirements of 10 CFR 50, Appendix E, Section IV.A.9. This analysis examined the capability of the minimum on-shift staff provided in DBNPS Emergency Plan Table 5-1A to perform the key emergency response actions for events described in ISG-01 until the augmenting staff arrived. The emergency response to each of the events described in ISG-01 was determined by conducting a tabletop of the event using the DBNPS Emergency Plan and emergency plan procedures and the applicable departmental procedures such as emergency and abnormal operating procedures. Each scenario was reviewed to determine the required plant actions and emergency plan implementation actions based on plant procedures prior to staff augmentation. These actions were then compared to the minimum on-shift staffing for emergency response implementation as described in Table 5-1A of the DBNPS Emergency Plan, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency response role or their dedicated operational role, as appropriate. ln cases where multiple tasks were assigned to an individual, the team evaluated the timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements. The analysis considered the station design basis accidents (DBA) described in the UFSAR along with additional scenarios specified by the guidance documents. The scenarios included in the analysis were the waste gas decay tank rupture, steam generator tube rupture (SGTR), main steam line break (MSLB), small break loss of coolant accident

Page 12o151 (LOCA) - outside containment, large break loss of coolant accident (LB-LOCA), fuel handling accident (FHA), design basis threat (DBT), probable aircraft threat (PAT), control room fire requiring control room evacuation and alternate shutdown, and station blackout (SBO). DBNPS Emergency Plan Table 5-1 specifies the minimum staffing requirements for the DBNPS on-shift staff, defines the positions initially responsible for satisfying key functions, and specifies positions that will augment the on-shift staff. ln support of this amendment request, an analysis of the post-shutdown on-shift staffing was conducted using the guidance in NEI 10-05. To properly address the permanently shutdown and defueled condition, the scenarios considered in the analysis included the waste gas decay tank rupture, FHA, control room fire requiring evacuation, a DBT, and a PAT. The SBO, the Anticipated Transient Without Scram (ATWS), and Appendix R fire were not considered in the post-shutdown on-shift staffing analysis. Once the certifications required by 10 CFR 50.82 are docketed, DBNPS will no longer be licensed to operate. The ATWS event would no longer be credible. The SBO rule (10 CFR 50.63) will no longer be applicable. Though 10 CFR 50, Appendix R will no longer be applicable, a fire consistent with the intent of NEI 10-05 was evaluated. This was a fire in the Control Room requiring Control Room evacuation. A summary of the results is presented in Section 4.5.1 of this enclosure. 4.2.2 Auqmented EmeroencvResponseOrqanizationStaffinq !n addition to the on-shift staffing requirements, which provide initial emergency response actions, DBNPS Emergency Plan, Section 5.0, "Organizational Control of Emergencies," describes the provisions for timely augmentation of on-shift personnel when required. The on-call (augmenting) ERO is described in DBNPS Emergency Plan Section 5.2, "DBNPS Emergency Management," Section 5.4, "Onsite Emergency Response Organization," and Section 5.5, "Near Site Emergency Response Facility." The augmented ERO is illustrated in Figure 5-2, pages 1 - 10. The DBNPS Emergency Plan defines four classes of emergency events: Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE) and General Emergency (GE). Because on-shift personnel can normally address an emergency response to UEs without additional support, staff augmentation may not be activated for a UE declaration, lf an Alert, SAE, or GE is declared, or if the minimum on-shift crew requires assistance during a UE, the onsite emergency organization will be augmented by additional plant personnel as described in Sections 5.4 and 5.5 of the DBNPS Emergency Plan. The DBNPS Emergency Plan describes the augmented emergency organization that will staff and operate the EOF, TSC, and OSC, each within one hour of the request for activation, and the JlC. The Shift Manager maintains command and control

Page 13 of 51 responsibility during UEs, unless the TSC has been activated. When declared operational, overall responsibility for the emergency is assumed by Emergency Plant Manager or Emergency Assistant Plant Manager in the Control Room or TSC, or the Emergency Director in the EOF. Procedures are in place to ensure the timely activation of ERFs. DBNPS Emergency Plan Section 5.8, "Supporting Emergency Organizations," describes the interfaces among the various offsite emergency organizations. 4.3 Accident Analysis DBNPS UFSAR Chapter 15 describes abnormal operational transients and DBAs that are applicable during plant operations. Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii), the 10 CFR 50 license for DBNPS wil! no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(aX2). Therefore, most of the accident scenarios postulated in the UFSAR will no longer be applicable. The postulated DBAs that will remain applicable to DBNPS in the permanently shutdown and defueled condition are the FHA in the SFP, and the waste gas decay tank rupture. UFSAR Chapter 15 will be revised to eliminate the DBAs that will not be applicable in the permanently shutdown and defueled condition. ln the permanently shutdown and defueled condition, DBNPS will be required to respond to events that involve a waste gas decay tank rupture, a FHA, a loss of SFP cooling or water inventory, and external events (for example, fire or hostile actions) that could lead to a loss of SFP cooling or water inventory. In addition, DBNPS will continue to implement the emergency response actions necessary to respond to potential aircraft impacts required by 50.54(hhx1) These strategies will be in place for the protection of the SFP. ln the permanently shutdown and defueled condition, the DBNPS Fire Brigade will implement the SFP inventory makeup strategies required under 10 CFR 50.54(hhx2). The strategies will no longer address restoration of core cooling and containment, since they are not applicable in the permanently shutdown and defueled condition. DBNPS will continue to maintain a trained and qualified Fire Brigade responsible for implementation of the SFP inventory makeup strategies. The Fire Brigade personnel identified in the DBNPS Emergency Plan are separate and distinct from those responsible for implementing the major elements of the emergency plan including command and control, emergency classification, offsite notifications, and dose assessment and protective action recommendation development. Therefore, sufficient staffing is available to implement SFP inventory makeup strategies required under 10 CFR 50.54(hhx2) without impacting the performance of designated emergency plan functions. As described in Section 4.4.7 of this evaluation, events involving a loss of SFP cooling or water inventory can be addressed by implementation of SFP inventory makeup

Page 14 of 51 strategies required under 10 CFR 50.54(hhx2). These strategies will continue to be maintained to satisfy applicable portions of DBNPS License Condition 2.C(8) of Renewed Operating License NPF-3. 4.4 FunctionalAreaTechnical Evaluation FENOC evaluated the proposed changes to the on-shift staffing to address the Major FunctionalAreas found in Table B-1 of NUREG-0654. The analysis addresses the on-shift staff for DBNPS and the augmented ERO for each function. The DBNPS Emergency Plan Table 5-1A identifies the following functional areas: o Plant Operations and Assessment of OperationalAspects

   . Emergency Direction and Control o   Notification and Communication o   RadiologicalAssessment o   Plant System Engineering, Repair and Mitigative Actions o   ln-Plant Protective Actions
   . Fire Fighting o   First Aid and Rescue
   . Site Access Control and Accountability An analysis of the proposed on-shift and augmented ERO staffing changes associated with DBNPS Emergency Plan Table 5-1A is provided for each Major Functional Area in Sections 4.4.1 through 4.4.9 that follows.

4.4.1 Maior FunctionalArea: Plant Operatio ns and Assessment of Ooerational Asoects 4.4.1.1 On-ShiftStaffinq The current minimum required on-shift staff to implement the DBNPS Emergency Plan, as detailed in Table 5-1A, in the Major FunctionalArea of Plant Operations and Assessment of Operationa! Aspects, consists of: o One (1) Shift Manager (SRO) o One (1) Unit Supervisor (SRO)

   . One (1) Shift Engineer (STA)
   . Two (2) Reactor Operators
   . One (1) Non-Licensed Operator

Page 15 of51 Proposed Chanoes Upon docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor, the on-shift staff in the Major Functional Area of Plant Operations and Assessment of OperationalAspects will be revised to eliminate:

   . One (1) Unit Supervisor (SRO) o   One (1) Shift Engineer (STA) o  Two (2) Reactor Operators 4.4.1.2     Auqmented ERO Table 5-18 of the DBNPS Emergency Plan does not identify augmented ERO personnel in the Major FunctionalArea of Plant Operations and Assessment of Operational Aspects. There are no proposed changes to the augmented ERO in this Major FunctionalArea.

4.4.1.3 Analvsis Plant operations on-shift staffing, as implemented for an operating nuclear power reactor, is based on the philosophy of defense-in-depth. Because of the reduced number of possible events requiring mitigating actions and the limited number of actions to be performed by the on-shift positions in the permanently shutdown and defueled condition, the monitoring and control responsibilities of the on-shift staff is limited to the operation of SFP support systems. The requirement for licensed ROs and the Unit Supervisor, who holds a SRO license is eliminated. ln accordance with the current technical specifications, the minimum shift crew composition requires ROs and SROs who are licensed by the NRC. The Shift Manager and the Unit Supervisor fulfill the requirements for the SROs, and the Reactor Operators fulfill the requirement for the ROs. In accordance with the DBNPS Emergency Plan, the Shift Manager, the Unit Supervisor, and the Reactor Operators support the Major Functiona! Area of Plant Operations and Assessment of Operational Aspects. Consistent with proposed changes to the DBNPS Technical Specifications (Reference 3) that revise the minimum shift staffing requirements and the position titles associated with SROs, ROs, and NLOs, the proposed positions will be fulfilled by individuals qualified as CFHs and NCOs. Because of the reduced number of possible events requiring mitigating actions in the permanently shutdown and defueled condition, and the limited number of actions to be performed by the on-shift positions, the Shift Manager and NCO positions would provide the resources needed to implement the DBNPS Emergency Plan. With DBNPS in a permanently shutdown and defueled condition, the operations staff will need to respond to events regarding a waste gas decay tank rupture, a FHA, a loss of SFP cooling or water inventory, and external events that could lead to a challenge to maintaining SFP cooling or water inventory. The Control Room continues to have indications, alarms, and controls related to SFP parameters.

Page 16 of51 The analysis of the proposed post-shutdown on-shift staffing, summarized in Section 4.5.1, validated that with DBNPS in a permanently shutdown and defueled condition, with the postulated accidents that would be applicable to that condition, the on-shift complement would be able to perform al! required Emergency Plan actions in a timely manner and that there are no identified collateral duties that would prevent the timely performance of emergency plan functions. The proposed on-shift staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50, commensurate with the reduced spectrum of credible accidents with DBNPS in the permanently shutdown and defueled condition, and that DBNPS retains the ability to implement the DBNPS SFP mitigation actions. 4.4.2 Maior FunctionalArea: Emeroencv Direction and Control 4.4.2.1 On-Shift Staffino The current minimum required on-shift staff to implement the DBNPS Emergency Plan, as detailed in Table 5-1A in the Major FunctionalArea of Emergency Direction and Control, consists of: a One (1) Shift Manager (This function may be performed by someone filling another position having functional qualifications) Proposed Chanqes There are no proposed changes to the DBNPS on-shift staff in the Major Functional Area of Emergency Direction and Control following permanent cessation of power operations and permanent remova! of fuel from the reactor vessel. 4.4.2.2 Ausmented ERO Table 5-1B of the DBNPS Emergency Plan identifies the Emergency Assistant Plant Manager as an augmented ERO position in this Major FunctionalArea. Additionally, DBNPS Emergency Plan Section 5.2.1, "Emergency Director," indicates that the designated Emergency Director or the Emergency Plant Manager can relieve the Shift Manager of emergency director responsibilities. There are no changes proposed to the augmented ERO in this Major FunctionalArea. 4.4.2.3 Analysis The responsibility of command and control resides with the Shift Manager. The Shift Manager assumes the responsibility of the Emergency Director and implements the DBNPS Emergency Plan in response to an emergency at the facility. The Emergency Plant Manager may assume the Emergency Director position upon arrival in the Control Room or TSC, and overall command and control of the emergency. The Emergency

Page 17 of 51 Assistant Plant Manager may assume the Emergency Director position upon arrival in the Control Room, and overall command and control of the emergency. The Emergency Director may assume the overall command and control of the emergency upon arrival in the TSC or EOF. The analysis of the proposed post-shutdown on-shift staffing, summarized in Section 4.5.1, validated that with DBNPS in a permanently shutdown and defueled condition, with the postulated accidents that would be applicable to that condition, the proposed DBNPS on-shift complement would be able to perform all required emergency plan actions in a timely manner and that there are no identified collateral duties that would prevent the timely performance of emergency plan functions. The proposed on-shift staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E commensurate with the reduced spectrum of credible accidents in a permanently shutdown and defueled condition, and that DBNPS retains the ability to implement the SFP mitigation actions. 4.4.3 Maior FunctionalArea: N otification and Communication 4.4.3.1 On-Shift Staffinq The current minimum required on-shift staff to implement the DBNPS Emergency Plan, as detailed in Table 5-1A in the Major FunctionalArea of Notification and Communication, consists of: a Licensee - CAS Operator (This function may be performed by someone filling another position having functional qualifications) a Local/State - NLO or above (This function may be performed by someone filling another position having functional qualifications) Federal - NLO or above (This function may be performed by someone filling another position having functional qualifications) Proposed Chanqes Aside from the previously discussed title change from NLO to NCO, there are no proposed changes to the DBNPS on-shift staff in the Major FunctionalArea of Notification and Communication following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. 4.4.3.2 Auqmented ERO Table 5-1B identifies the State/County Communicator as an augmenting position in the EOF. There are no proposed changes to the augmented ERO in this Major Functional Area.

Page 18 of51 4.4.3.3 Analysis 10 CFR 50, Appendix E, Section lV.D.3 requires licensees have the capability to notify responsible State and local government agencies within 15 minutes after declaration of an emergency. 10 CFR 50.72(a)(3) requires licensees to notify the NRC immediately after notification of the appropriate State or local agencies and not later than 60 minutes after declaration of one of the emergency classifications. This function is currently performed by an on-shift NLO (or a qualified individual in another position) performing the communicator functions. This function is currently augmented by the State/County Communicator in the EOF. DBNPS uses a dedicated 4-way phone system located in the Control Room and EOF to support the Notification and Communication function. lt is used to transmit information to the State and County Emergency Operations Centers (EOCs), the Ohio Highway Patro! Office, and the Lucas County and Ottawa County Sheriffs dispatcher offices for UEs, Alerts, SAEs, and GEs. This system is available on a 24-hour basis and incorporates each principal emergency response center into a single dedicated network. ln addition, each organization can be reached via norma! commercial lines as a backup to the 4-way phone system. NRC notifications are treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it is assumed that the NRC will request an open line to be continuously maintained with the NRC Operations Center using the dedicated Emergency Notification System (ENS) network. The use of dedicated phone circuits enables these notifications to be performed by the same on-shift communicator who performs the State and local notifications. There are no proposed changes to the on-shift or augmented ERO staff in the Major FunctionalArea of Notification and Communication following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The analysis of the proposed post-shutdown on-shift staffing, summarized in Section 4.5.1, validated that with DBNPS in a permanently shutdown and defueled condition, with the postulated accidents that would be applicable to that condition, the DBNPS on-shift complement would be able to perform required emergency plan actions in a timely manner and that there are no identified collateral duties that would prevent the timely performance of emergency plan functions prior to augmentation. The proposed on-shift staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, commensurate with the reduced spectrum of credible accidents in in a permanently shutdown and defueled condition, and that DBNPS retains the ability to implement the SFP mitigation actions.

Page 19 of51 4.4.4 Maior Functional Area: Radioloqical Assessment 4.4.4.1 On-Shift Staffinq The current minimum required on-shift staff to implement the DBNPS Emergency Plan, as detailed in Table 5-1A in the Major FunctionalArea of RadiologicalAssessment, consists of: o Dose Assessment - Shift Engineer (STA) (This function may be performed by someone filling another position having functional qualifications) o ln-Plant Surveys - RP Technician

    . Onsite Surveys - RP Technician (This function may be performed by someone filling another position having functiona! qualifications)
    . Chemistry - Chemistry Technician Proposed Chanoes Upon permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS on-shift staff in the Major FunctionalArea of Radiological Assessment will be revised to eliminate the on-shift Chemistry Technician and the Shift Engineer (STA) Any required duties will be retained as a collateral duty of other qualified on-shift staff.

4.4.4.2 Auqme nted ERO Table 5-1B of the DBNPS Emergency Plan is revised to eliminate the 1 - 2 hour augmenting Chemistry Technician. 4.4.4.3 Analvsis The on-shift Chemistry Technician and the Shift Engineer (STA) are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The on-shift Chemistry Technician is responsible for performing post-accident chemistry samples and analyses and supporting operations in the area of chemistry as directed by the Shift Manager. However, the analysis of the proposed post-shutdown on-shift staffing indicates that no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. Currently, the Chemistry Technician is an on-shift position so that a technician is always available to collect and analyze a liquid sample if the applicable radiation monitor is not available during a release, or as directed by the Shift Manager. When the on-shift Chemistry Technician position is eliminated, the function will be maintained by having trained and qualified personnel on-shift to perform sampling and analysis requested by the Shift Manager to determine if an emergency declaration is required.

Page 20 of 51 Specific knowledge requirements would include how to obtain specific liquid samples. The initial training requirements for the designated on-shift person will include the training modules needed to ensure they are equipped with the required skills and knowledge to perform the required liquid sampling and analysis. These training modules will be specifically identified in their training program description for the designated on-shift person position. This training will be developed in accordance with the requirements of 10 CFR 50.120. For gaseous releases, the most limiting scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object. Plant activities that could cause mechanical damage will require the radiation monitor listed in gaseous effluent EALs be in service or that a Chemistry Technician be onsite, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. Applicable fuel handling procedures will be revised to require that the radiation monitor listed in gaseous effluent EALs be in service or that a Chemistry Technician be onsite as a prerequisite prior to fue! handling activities. This is a regulatory commitment and is listed in Attachment 5. The NRC requires that the DBNPS Emergency Plan maintain a level of effectiveness commensurate with the potential consequences to public health and safety and common defense and security. With the permanent cessation of power operations and the permanent removal of the fue! from the reactor vessel, most of the accident scenarios postulated for an operating power reactor are no longer possible. The reactor, reactor coolant system (RCS), and reactor support systems are no longer in operation and have no function related to the storage of the irradiated fuel. Therefore, postulated accidents involving failure or malfunction of the reactor, RCS, or reactor support systems are no longer credible. The on-shift Shift Engineer (STA) is currently responsible for performing initial dose assessment activities. The purpose of conducting the offsite dose assessment is to review radiological conditions using data from available instrumentation, assess the impact of changing radiological conditions on emergency classification, assist in accident assessments based upon those changing radiological conditions, and recommend appropriate offsite protective measures. Dose assessment will no longer be required to evaluate multiple release paths, because the permanent defueled status will prohibit operation of the reactor, and these paths are only applicable to an operating unit. The only path that will be required to be assessed is the path in which the SFP source term potentially could be discharged. ln the analysis of the post-shutdown on-shift staffing the NCO is used to perform the dose assessment function. The use of the NCO to support the on-shift dose assessment is appropriate for a permanently shutdown and defueled condition because many of the potential initiating conditions that would lead to an emergency declaration

Page 21 of 51 are no longer credible. The set of plant equipment involved in this condition is also greatly reduced, which also reduces the need for assessments and mitigation activities for an emergency. lmplementation of these proposed ERO changes maintains the chemistry sampling and dose assessment functions by using other trained on-shift staffing, and will continue to meet the planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E, commensurate with the reduced spectrum of credible accidents with DBNPS in the permanently shutdown and defueled condition. The proposed changes to the augmented ERO following permanent cessation of power operations and permanent removal of fue! from the reactor vessel includes the elimination of the 1 - 2hour augmenting Chemistry Technician position. The need to perform complex chemistry sampling is greatly reduced with the permanent cessation of power operations and the source term confined to the SFP. There is no need to dispatch a Chemistry Technician to support sampling. The on-shift staffing will be adequate to perform sampling of the SFP. However, if conditions warrant, Chemistry personnel are availabb to be called in by the OSC Manager. lmplementation of these changes do not impact the overal! effectiveness to perform the necessary emergency planning functions and will not cause undue impact to the performance of the DBNPS Emergency Plan. 4.4.5 Major FunctionalArea Plant Svstem Enoineerino. Repair and Mitiqative Actions 4.4.5.1 On-Shift Staffino The current minimum required on-shift staff to implement the DBNPS Emergency PIan, as detailed in Table 5-1A in the Major FunctionalArea of Plant System Engineering, Repair and Mitigative Actions, consists of: a Technical Support - Ops - Shift Engineer (STA) (This function may be performed by someone filling another position having functional qualifications) a Technical Support - Core Damage - Shift Engineer (STA) (This function may be performed by someone filling another position having functional qualifications) a Repair and Mitigative Actions - Mechanical Repair, Electrical Repair, l&C Repair (This function may be performed by someone filling another position having functional qualifications) Proposed Chanqes Upon docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS on-shift staff in the Major FunctionalArea of Plant System Engineering, Repair and Mitigative Action will be revised to eliminate the on-shift Shift Engineer (STA).

Page 22 of 51 4.4.5.2 Auomented ERO Table 5-1B of the DBNPS Emergency Plan is revised to reduce the augmenting Mechanical Maintenance Technicians from two (2) to one (1). Table 5-1B of the DBNPS Emergency Plan is revised to reduce the augmenting Electrical Maintenance Technicians from two (2) to one (1). Table 5-1B of the DBNPS Emergency Plan is revised to eliminate the two (2) augmenting lnstrument & Contro! Technicians (l&C). Table 5-1B of the DBNPS Emergency Plan is revised to eliminate the augmenting Core/Thermal Hyd raulics Engineer. Table 5-1B of the DBNPS Emergency Plan is revised to eliminate the augmenting Mechanical Engineer. Table 5-1B of the DBNPS Emergency Plan is revised to eliminate the augmenting Electrical Engineer. Table 5-1B of the DBNPS Emergency Plan is revised to eliminate the augmenting l&C Engineer. 4.4.5.3 Analysis The Shift Engineer (STA) performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations. The Shift Engineer (STA) also contributes to operations during normal plant conditions. By routine monitoring of equipment and plant operations, the Shift Engineer (STA) can focus on preventative actions to mitigate the consequences of an accident. Because of the permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the Shift Engineer (STA) position is no longer necessary for technical and analytical assistance. The Technical Support function will be assumed by the remaining on-shift personnel. The analysis of the proposed post-shutdown on-shift staffing concluded that the DBNPS on-shift Shift Manager (CFH) and NCOs can perform any required technical analysis, until augmented by the TSC, in a timely manner, and there are no collateral duties that would prevent the performance of this task. Currently, the on-shift complement does not include dedicated maintenance personnel. ln accordance with Table 5-1A notes, mechanical repair, electrical repair, and l&C repair expertise may be provided by on-shift personnel assigned other functions. During initial stages of an event, the scope of repair and corrective actions performed by on-shift personnel will typically be limited to actions that promptly restore a non-functional component or system to a functional status (that is, resetting a relay or logic

Page 23 of 51 manipulation) or to place a component or system in a desired configuration such as opening a valve or closing a breaker. The DBNPS on-shift NCOs have the expertise to perform this level of minor maintenance actions as directed by the Shift Manager and are available to satisfy any minor troubleshooting and repair activities that might be needed until the augmenting staff arrives. The analysis of the proposed post-shutdown on-shift staffing concluded that no maintenance activities were required until augmenting personnel arrived. The proposed changes to the augmented ERO following permanent cessation of power operations and removal of fuel from the reactor vessel include the elimination of one (1) augmenting Mechanical Maintenance position, one (1) augmenting Electrical Maintenance position, and the augmenting l&C Technician positions. DBNPS proposes to maintain the OSC Manager position, and a pool of one (1) augmenting Mechanical Maintenance Technician and one (1) augmenting Electrical Maintenance Technician, to support repair and corrective actions. ln the permanently shutdown and defueled condition there are no complex automatic control systems in service. The need for dedicated l&C technicians is not required. lf conditions warrant, the OSC Manager can call out l&C support as necessary. The current DBNPS ERO staffing is intended to address the risks to public health and safety inherent in an operating reactor. The risk with DBNPS in the permanently shutdown and defueled condition is significantly reduced. Many of the potential initiating conditions that would lead to an emergency declaration will no longer be credible. The set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, which reduces the assessments and mitigation activities that the OSC must perform. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safe storage of spent fuel is reduced, as compared to an operating power reactor. Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC with DBNPS in a permanently shutdown and defueled condition. The OSC Manager will continuously evaluate the need for resources. !f conditions warrant, the OSC Manager can call out additional maintenance support as necessary OSC resources will continue to be augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The primary events of concern in the post-shutdown and defueled condition will be a waste gas decay tank rupture, a fuel handling accident, a loss of SFP cooling or water inventory, and external events. Events involving a loss of SFP cooling or water inventory can be addressed by implementation of the SFP inventory makeup strategies, as required by 10 CFR 50.54(hhx2). OSC staff is not relied upon to implement SFP inventory makeup. As such, elimination of the augmenting Mechanical Maintenance, Electrical Maintenance, and lnstrument & Control Technician positions do not impact the ability of the ERO to perform repair functions based on the permanent shutdown and defueled condition of DBNPS.

Page 24 of 51 Table 5-1B identifies the Core/Therma! Hydraulics Engineer as an augmented responder (30 minutes during norma! hours) to the TSC. The proposed change eliminates this position. The primary duty of the TSC Core/Therma! Hydraulics Engineer is to perform core damage assessments. ln a permanently shutdown and defueled condition, responsibilities associated with assessing a reactor core are no longer needed. Elimination of the TSC Core/Thermal Hydraulics Engineer position will have no effect on emergency response in a permanently defueled condition because the position is not required to assess the condition of fue! in the SFP during an emergency. The TSC Core/Thermal Hydraulics Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core conditions or thermal hydraulics is not necessary or possible in a permanently shutdown and defueled condition. Table 5-1B identifies Mechanical, Electrical and l&C Engineers as augmented responders to the TSC. The proposed changes eliminate these positions. The primary duties of the TSC Engineer positions include: providing engineering analysis and troubleshooting, evaluating the implementation of Severe Accident Management Guidelines, and assisting in the assessment and development of repair plans. These duties, described in implementing procedures, are either no longer necessary in a permanently shutdown and defueled condition or can be performed by other members of the post-shutdown ERO. The TSC Engineering Manager is tasked with performing an engineering assessment of plant conditions and actions needed to mitigate damage to the plant. Engineering functions will continue to be performed by supplementa! engineering resources that will respond and be utilized, as required. DBNPS EPIPs will continue to direct the TSC Engineering Manager to continuously evaluate the need for engineering resources and call in additional engineering assistance, as needed. These individuals may be tasked with activities to be completed at engineering offices externalto the TSC, called to report to the TSC, or directed to other facilities as needed. DBNPS EPIPs will continue to identify engineering resources as augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. However, these positions will no longer be identified as on-call positions. The elimination of the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. The proposed changes to the ERO staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E, commensurate with the reduced spectrum of credible accidents in the permanently defueled condition, and ensures that DBNPS retains the ability to promptly implement SFP mitigation actions.

Page 25 of 51 4.4.6 Maior FunctionalArea: ln-Plant Protective Actions 4.4.6.1 On-Shift Staffino The current minimum required on-shift staff to implement the DBNPS Emergency Plan, as detailed in Table 5-1A in the Major FunctionalArea of ln-Plant Protective Actions, consists of: a Two (2) Radiation Protection Technicians (This function may be performed by someone filling another position having functional qualifications) Proposed Chanqes Upon docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS on-shift staff in the Major FunctionalArea of ln-Plant Protective Actions will be revised to reduce ln-Plant Protective Action Radiation Protection Technicians (or individuals filling other positions but having functiona! qualifications) from two (2) to one (1). 4.4.6.2 Auomented ERO Table 5-1B of the DBNPS Emergency Plan is revised to reduce the augmenting Radiation Protection Technicians from four (4) to two (2). 4.4.6.3 Analysis Table 5-1A notes Operations personnel are qualified on survey instruments. This qualification reduces the need for an additional responder in the area of ln-Plant Protective Actions until augmenting staff arrives. The proposed changes to the augmented ERO following permanent cessation of power operations and removal of fuel from the reactor vessel include eliminating two (2) of the four (4) augmenting Radiation Protection Technicians. The function of these resources is to provide radiation protection oversight of the complement of personnel for emergency repair, search and rescue, first aid, firefighting, and personne! monitoring. Once the ERO is activated, the two (2) augmenting Radiation Protection Technicians willjoin the on-shift Radiation Protection Technician providing three (3) personnel to support station emergency plan activities. The need for radiation protection oversight of personnel has been greatly reduced due to technological advances. Originally, radiological access controlwas a labor intensive task. Dedicated Radiation Protection Technicians were required to check dose margins, training qualifications, and ensure workers had read and understood the radiation protection work permit. Worker access contro! is now automated because radiation protection work processes have been computerized. Radiation Work Permit (RWP) access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on RWPs and to self-issue electronic dosimeters. During a declared emergency, Radiation Work Permits (RWPs)

Page 26 of 51 and dose set points will change depending on the emergency and plant conditions. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access contro! system is used. lf a worker's dose margin is inadequate or training is expired, the worker's access would be precluded and the access control system would not allow issuance of an electronic dosimeter. ln an emergency, approval to exceed dose margins is required. During the log-in process, workers acknowledge their electronic dosimeter alarm set points and that they have read and understand their RWP. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates and will alarm at preset dose and dose rates. Worker use of electronic dosimeters facilitates more efficient use of Radiation Protection Technicians to provide Radiation Protection coverage while preserving the As Low As Reasonably Ach ievable (ALARA) concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter a radiation work permit number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the RWP access contro! computers, which allows Radiation Protection Technicians to be used for more criticaltasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No Radiation Protection Technician involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight. However, contaminated personne! exiting the RCA wil! require Radiation Protection oversight. This oversight can be performed by the augmented Radiation Protection Tech n icians. For a permanently shutdown and defueled condition, the evaluated accidents are limited to the SFP area. Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFP are limited, there is a significant decrease in the areas potentially requiring radiation protection coverage. Repair teams can be covered by the on-shift radiation protection personnel. lf radiation protection coverage is not provided (for entry into areas with low radiological risk or known radiological conditions), work protection is still ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate set points) and because of the installed area radiation monitors that alarm locally and remotely at preset dose rates located throughout the plant. Therefore, three (3) Radiation Protection Technicians will be capable to providing adequate protective actions to support plant activities with DBNPS in the permanently shutdown and defueled conditions. The proposed change to the ERO staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E, commensurate with the reduced spectrum of credible accidents in the permanently defueled condition and ensures that DBNPS retains the ability to promptly implement SFP mitigation actions.

Page 27 ol 51 4.4.7 Maior FunctionalArea: Fire Fiohtinq 4.4.7.1 On-Shift Staffino The current minimum required on-shift staff to implement the DBNPS Emergency Plan, as detailed in Table 5-1A in the Major FunctionalArea of Fire Fighting, consists of: o Fire Brigade Captain (RO/EO3)

    . Four (4) Fire Brigade Members Proposed Changes Upon docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the DBNPS on-shift staff in the Major Functional Area of Fire Brigade will be revised to remove the reference of RO/EO3 personnel. Required duties will be retained and performed by trained and qualified personnel.

4.4.7.2 Auqmented ERO DBNPS Emergency Plan Table 5-1B does not identify augmented ERO in the Major FunctionalArea of Fire Fighting. There are no proposed changes to the augmented ERO in this Major FunctionalArea. 4.4.7.3 Analvsis The Fire Brigade wi!! continue to be staffed in accordance with the DBNPS Fire Hazards Analysis Report. Fire Brigade training and qualification requirements will be maintained in accordance with site procedures. The Fire Brigade will continue to perform the task of firefighting with DBNPS in the permanently shutdown and defueled condition. The Fire Brigade will be available to implement SFP inventory makeup strategies required under 10 CFR 50.54(hhx2) without impacting the performance of designated emergency plan functions. 4.4.8 Maior Functional Area: First Aid and Rescue Aside from the previously described title change from NLO to NCO, there are no proposed changes to the DBNPS on-shift staff in the Major Functional Area of First Aid and Rescue following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. 4.4.9 Major FunctionalArea: Site Access Control and Accountabilitv There are no proposed changes to the DBNPS on-shift staff in the Major Functional Area of Site Access and Accountability following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

Page 28 of 51 4.5 Emerqency Response Oroanization Chanoes - Emeroencv Response Facilitv Evaluation NUREG-0654 (Reference 1), Section l!.B, "Onsite Emergency Organization," presents guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section lV.A. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies." DBNPS Emergency Plan Section 7.0, "Emergency Facilities and Equipment," describes the DBNPS ERFs. These facilities include the Control Room, TSC, OSC, EOF, and JIC. The following sections address the impact of the proposed augmented ERO staffing changes on each ERF. The Control Room contains the necessary instrumentation for operating the plant under normal and accident conditions. The Control Room is continuously staffed, Control Room personne! make the initial declaration and classification of an emergency and perform activities of the other ERFs until those facilities are operational. Manipulations of the reactor or the plant to mitigate the consequences of an accident and restore safe conditions, however, remain as the primary function of the Control Room. Upon permanent cessation of power operations and the permanent removal of the fuel from the reactor vessel, irradiated fue! will be stored both in the SFP and in the ISFSI. After an appropriate time period, the irradiated fuelwill be transferred from the SFP to the lSFSl. At this point the irradiated fuel wil! be stored at the ISFSI unti! it is permanently removed from the site. Upon docketing of the certifications for permanent cessation of power operations, 10 CFR 50.82(a)(1)(i), and permanent removal of fuel from the reactor vessel, 10 CFR 50.82(a)(1)(ii), pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vesse!. As a result, the reactor, RCS, and reactor support systems, will no longer be in operation. These systems have no storage function for irradiated fuel. Therefore, postulated accidents involving a failure or malfunction of the reactor, RCS, or reactor support systems are no longer applicable. During facility decommissioning, the principal public safety concerns involve the radiological risks associated with the storage of spent fuel onsite. The proposed level of onsite operations staff will continue to provide for communication and coordination capabilities with offsite organizations for the level of support required for the remaining DBAs and the prompt implementation of mitigative actions in response to an SFP accident. The "FunctionalArea Technical Evaluation," presented in Section 4.4, concluded that the proposed on-shift staffing changes do not impact the capabilities of the DBNPS on-shift staff to respond to an emergency and continues to comply with the DBNPS Emergency Plan, site commitments, and regulations.

Page 29 of 51 4.5.1 On-Shift Staffins - Control Room To support the reductions in on-shift staffing following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing levels were evaluated using the NEI 10-05 methodology. The results supported the changes to the on-shift staff provided in Table 4.5-1 of this enclosure. Table 4.5-1 Proposed Post-Shutdown Position Current On-Shift Staffing Staffinqr Control Room Staff Shift Manaqer 1 I Unit Supervisor 1 Shift Enqineer (STA) 1 Reactor Operators 2 NLOs / NCOs 1 2 Control Room Totals 6 3 Other On-shift Positions RP Technicians 1 1 Chemistrv Technician I 1 Fire Brigade Captain 1 Fire Brigade Captain Fire Brigade2'3 (RO/EO3) (NCO identified above) 4 Fire Brioade Members 4 Fire Brioade Members Site Access Control and 1 Security Shift Supervisor 1 Security Shift Supervisor Accountability 1 CAS Operator 1 CAS Operator Other Totals o 7 TOTAL 15 10 1 A dash (--) indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan. 2 ln accordance with the Fire Hazards Analysis Report, the Fire Brigade is comprised of one (1) Fire Brigade Captain and four (4) Fire Brigade members. 3 The current on-shift Fire Brigade is comprised of one (1) Fire Brigade Captain that may either be a Reactor Operator or an NLO and four (4) individuals that may either be Reactor Operators or NLOs. The post-shutdown Fire Brigade will remain as five (5) qualified individuals. The Fire Brigade Captain will be an NCO, while the four (4) brigade members may not be NCOs. 4.5.1.1 Post-Shutdown On-Shift Staffins Analysis The analysis of the proposed post-shutdown on-shift staffing evaluated the ability of the proposed post-shutdown on-shift staff to implement the DBNPS Emergency Plan following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents that could occur with DBNPS in the permanently shutdown and defueled condition. DBNPS will ensure a sufficient number of personnel are trained to support the on-shift positions prior to implementation of the post-shutdown emergency plan changes.

Page 30 of 51 Consistent with the methodology of NEI 10-05, the current on-shift staffing analysis evaluated postulated DBA scenarios. DBNPS UFSAR Chapter 15 describes the abnormal operationaltransients, off-design operationaltransients, and DBA scenarios that are applicable during plant operations. Upon docketing of the certifications required by 10 CFR 50.82(aX1), the 10 CFR 50 license for DBNPS wi!! no Ionger authorize operation of the reactor or emplacement or retention of fue! into the reactor vesse!, as specified in 10 CFR 50.82(a)(2). Post shutdown, the reactor, RCS, and reactor support systems will no longer be in operation As a result, postulated accidents involving a failure or malfunction of the reactor, RCS, or reactor support systems are no longer applicable. Therefore, most of the accident scenarios postulated in the UFSAR will no longer be applicable once DBNPS is permanently shutdown and defueled. The postulated DBAs that will remain applicable to DBNPS in its permanently shutdown and defueled condition are the FHA in the SFP and the waste gas decay tank rupture. DBNPS UFSAR Chapter 15 will be revised to eliminate the accidents that will not be applicable in the permanently shutdown and defueled condition. The following accident scenarios were evaluated in the DBNPS post-shutdown staffing analysis: Waste Gas Decav Tank Rupture The rupture of a waste gas decay tank would release the entire contents of the tank to the Auxiliary Building atmosphere. The Auxiliary Building is ventilated and discharged to the station vent. ln the analysis, however, the activity is assumed to be released from the waste gas decay tank to the atmosphere over a two-hour period. Desiqn Basis Threat The event consists of notification to the Shift Manager from the Security Shift Supervisor that a hostile action is occurring at or inside the Protected Area. A hostile force will breach the Protected Area fence, but there are no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components is not sufficient to cause a radiological release. There is no fire significant enough to warrant firefighting efforts prior to the arrival of offsite resources and/or the augmented ERO. The event accounts for the expected constraints on the movement of personnel (for example, movement not allowed, limited movement using the two-person rule, and so forth). Specifically, individuals must usually be in, or readily able to respond to, assigned response locations before being credited with performing a function or task that implements the emergency plan. An analysis objective is to confirm that sufficient staff is available to simultaneously implement both the emergency plan and the security plan.

Page 31 of51 Fuel Handlinq Accident (FHA) with General Emerqencv and Protective Action Recommendation The FHA event analyzes an event involving mechanical damage to the fuel assemblies during transfer operations and a dry fuel storage cask drop accident. Dry fuel storage cask movement would include numerous extra personnel present for the activity. There will not be a time during dry fue! storage cask movement when only the minimum on-shift ERO is present. The dry fuel storage cask drop event is not included in the proposed post-shutdown on-shift staffing analysis. The event consists of a fuel assembly striking a sharp object or dropped fuel assembly in the SFP, resulting in fuel cladding integrity failure. This event assumes a dose that exceeds the Environmental Protection Agency's (EPA) Protective Action Guides (PAGs) beyond the site boundary, and thus necessitates promulgation of a Protective Action Recommendation (PAR). Aircraft Probable Threat [10 CFR 50.54(hh)] This event includes a!! emergency response actions taken prior to an aircraft impact in accordance with Regulatory Guide 1.214, "Response Strategies for Potential Aircraft Threats," Rev 1, March 2014, for an aircraft threat that is greater than 5 minutes, but Iess than 30 minutes, from the site, including the dispersal of the Fire Brigade away from target areas. These actions should generally reflect those listed in 10 CFR 50.54(hh)(1), as expanded upon in Regulatory Guide 1.214, and others required by the emergency plan. The event consists of notification to the Shift Manager from the NRC Headquarters Operations Officer that an Aircraft Probable Threat has been declared for DBNPS. Fire Requirinq Evacuation of the Control Room and Control of SFP Coolinq A fire occurs requiring the evacuation of the Control Room and procedures implemented to control SFP cooling from a remote location. The SBO, the ATWS, and the Appendix R fire were not considered in the post-shutdown on-shift staffing analysis. Once the certifications required by 10 CFR 50.82 are docketed, DBNPS will no longer be licensed to operate. Hence, an ATWS is not considered credible, and 10 CFR 50.63 and 10 CFR 50, Appendix R will no longer be applicable. Though 10 CFR 50, Appendix R will no longer be applicable, a fire consistent with the intent of NEI 10-05 was evaluated. This was a fire in the Control Room requiring Control Room evacuation.

Page 32 of 51 The spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor, and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to an operating plant. The primary events of concern in the post-shutdown and defueled condition will be a waste gas decay tank rupture, a FHA, a loss of SFP cooling or water inventory, and external events. During fuel handling activities, there will ordinarily be extra personnel onsite to assist with fuel movement, in addition to minimum on-shift staff. Loss of SFP cooling or water inventory can be addressed by implementation of normal and emergency SFP inventory makeup strategies and mitigating strategies required under License Condition 2.C(8) of Renewed Operating License NPF-3. The analysis of the proposed post-shutdown on-shift staffing validated that with DBNPS in a permanently shutdown and defueled condition, the staffing presented in Table 4.5-1 can perform required post-shutdown emergency plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of post-shutdown emergency plan functions. The proposed on-shift staffing changes continues to comply with the DBNPS Emergency Plan, site commitments, and applicable regulations. 4.5.2 Auqmented Emerqency Response Orqanization The proposed augmented ERO changes described in this submittalwill be implemented following docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel. Prior to an emergency declaration, the normal plant operating organization is in place. The initial classification of an off-normal event and declaration are performed by the on-shift Shift Manager. Upon classification and declaration of an emergency, the Shift Manager assumes the role of Emergency Director and retains that role until another qualified Emergency Director can assume control. lnitially, the ERO consists of the normal operating shift personnel. The normal operating staff is augmented by qualified plant personnel. Those personne! onsite respond when the station alarm is sounded and an announcement is made, or when individuals are notified by another means. Personnel not onsite will be notified via an ERO notification system. Designated on-shift personnel perform the notifications. ln the permanently shutdown and defueled condition, DBNPS will maintain multiple ERO teams to respond to an emergency declaration, with one complete team on-duty at any given time. When the Shift Manager directs the activation of the ERO call-out system, all ERO members are notified to ensure adequate coverage of ERO positions at each ERF. ERO members not on-call are expected to respond unless they are unavailable.

Page 33 of 51 DBNPS requires ERO personnel to act promptly in reporting to their assigned ERF even when not on-duty. During duty periods, an EPIP requires that team members respond within the required response time to their ERF (unless a longer time frame is specified for their specific ERO position) and that on-call ERO members remain fit for duty throughout the duty assignment. Individuals are trained to respond to their ERF even if they are not on-duty. Excess personnelthat respond may be assigned support responsibilities or be designated as a relief shift. This conservative policy ensures timely activation because some off-duty personnel may respond sooner than the on-duty personnel. The proposed revisions to the DBNPS Emergency Plan will not change the requirements described above. Management's continued expectation is that duty and support ERO members report to their respective ERF as quickly as possible. ERO personnel are expected to respond when notified by the ERO notification system. Procedures identify ERO positions assigned to each ERF and the minimum staffing required before each facility can be declared operational and available to perform its designed functions. The procedures will continue to assign responsibilities to ERO responders, with the purposes of removing the responsibilities of coordinating with offsite responders and delivering information to the public from the Control Room, allowing on-shift personnel to focus on returning the facility to a safe condition. The risk in the permanently shutdown and defueled condition is significantly reduced, since many of the potential initiating conditions that would lead to an emergency declaration will no longer be credible. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessments and mitigation activities the ERO staff (TSC, OSC, or EOF) must perform. Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC staff in a permanently shutdown and defueled condition. 4.5.2.1 Technical Support Center Auqmentins Positions DBNPS Emergency Plan Section 5.4.4, "Technical Support Center (TSC) Organization," describes the key DBNPS ERO positions and associated responsibilities, including augmented ERO positions that respond to the TSC. Table 4.5-2 identifies those augmented ERO positions that respond to the TSC following an emergency declaration and the proposed changes to the post-shutdown augmented ERO responding to the TSC.

Page 34 of 51 Table 4.5-2 Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented ERO Positions Positionsl Technical Support Genter Emergency Plant Manaqer Emergency Plant Manager Emergency Assistant Plant Manager2 Emergency Assistant Plant Manager3 Recovery Advisor TSC Engineering Manager TSC Engineering Manager TSC Engineerinq Lead TSC Operations Lead TSC Engineers (Mechanical, Electrical, Mechanical, Electrical, l&C, Operations - l&C, Operations) Available to respond on an as-needed basis as determined bv the TSC Enoineerinq Manaqer Core/Thermal Hydraulics Engineer TSC Computer Technician SAM Engineer Emergency RP Manager Emergency RP Manager Emergency Security Manager Emergency Security Manager OCA Security Supervisor OCA Security Supervisor 1 A dash (--) indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan. 2 ln the current DBNPS Emergency Plan, the Emergency Assistant Plant Manager reports to the Control Room. 3 ln the proposed DBNPS Emergency Plan, the Emergency Assistant Plant Manager may report to the TSC. The TSC is located in the Davis-Besse Administration Building (DBAB). Following permanent cessation of power operations and permanent removal of fue! from the DBNPS reactor vessel, the TSC will continue to be located in the DBAB. The changes proposed to the DBNPS Emergency Plan do not involve any physical modifications to, or layout and configuration changes in, the TSC. The current DBNPS Emergency Plan is intended to address the risks to public health and safety inherent with an operating reactor. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. Therefore, the Recovery Advisor, TSC Engineering Lead, TSC Operations Lead, TSC Engineers (Core/Thermal Hydraulics, Mechanical, Electrical, l&C, and Operations), SAM Engineer, and the TSC

Page 35 of 51 Computer Technician positions can be eliminated without placing an undue burden on the remaining ERO positions in the TSC and without increasing the risk to public health and safety. The proposed augmented ERO staffing reductions continue to address the risks to public health and safety, comply with the DBNPS Emergency Plan, site commitments, and applicable regulations. The proposed staffing changes to the TSC eliminates the TSC Engineers (Core/Thermal Hydraulics, Mechanical, Electrical, l&C, Operations, and SAM). The TSC EPIP indicates that a combination of three (3) of the aforementioned engineers provide minimum staffing that would be necessary to declare the TSC operational. The primary duties of the TSC Engineer positions include monitoring plant conditions for any indication of core damage, responding to engineering requests from the Engineering Manager, evaluating the implementation of Severe Accident Management Guidelines, and assisting the OSC in preparing to send repair teams into the plant. These duties are either no longer necessary in a permanently shutdown and defueled condition or can be performed by the TSC Engineering Manager. The TSC Engineering Manager will be tasked with performing engineering assessments of plant conditions and/or actions needed to mitigate damage to the plant. After docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. Thus, the need for augmenting engineers is reduced. The TSC Engineering Manager, tasked with performing engineering assessments of plant conditions and actions needed to mitigate damage to the plant, will provide technical support in the Major FunctionalArea of Plant System Engineering, Repair, and Corrective Action. The TSC Engineering Manager will have the necessary qualifications, expertise, and capabilities to perform engineering assessments of plant conditions and actions needed to mitigate damage to the plant in response to a fuel handling accident or an event resulting in damage to the SFP integrity or the loss of SFP cooling or inventory. With respect to responding to engineering requests from the TSC Engineering Manager, this function will continue to be performed by supplementing qualified engineering resources. The TSC Engineering Manager will continuously evaluate the need for engineering resources and call in qualified engineering personnel, as needed. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities. Engineering resources will continue to be available, as supplemental positions, with specific training and qualification requirements for assigned personnel in accordance with the site training program. However, these positions will no longer be identified as on-call positions. Eliminating the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity

Page 36 of 51 of activities required for the safe storage of spent nuclear fue! is reduced as compared to an operating plant. The set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. The Recovery Advisor's primary duties are to collect plant and equipment status in preparation for entering the recovery phase and ensuring the Outage Control Center is set up for a forced outage during recovery. After docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. Thus, the Recovery Advisor is not needed. The TSC EPIP does not identify the TSC Engineering and Operations Lead positions as minimum staffing that would be necessary to declare the TSC operational. The duties of the TSC Engineering Lead include coordination of the TSC engineering activities. The duties of the TSC Operations Lead include coordination of the TSC operations engineering activities. With the removal of the TSC Engineers from the TSC, the Lead positions are no longer necessary. The TSC Engineering Manager coordinates engineering activities. The elimination of the TSC Computer Technician position does not impact the capabilities of the on-shift staffing or augmented response. The TSC will continue to be activated at an Alert or higher declaration. Functional responsibilities of the eliminated positions, as a result of the proposed changes, will be reassigned to remaining positions, as necessary. contains an analysis of the TSC augmented ERO positions proposed for elimination and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The analysis evaluates and dispositions each ERO task as being reassigned or eliminated, as appropriate. Based on the analysis, given the elimination of credible accidents involving an operating reactor, the proposed post-shutdown augmented ERO can continue to satisfactorily perform their existing Emergency Plan responsibilities as well as any transferred responsibilities. 4.5.2.2 Operations Support Center Auqmentino Positions DBNPS Emergency Plan Section 5.4.5, "Operations Support Center (OSC) Organization," describes the key DBNPS ERO positions and associated responsibilities, including augmented ERO positions that respond to the OSC. Table 4.5-3 identifies those augmented ERO positions that respond to the OSC following an emergency declaration and the proposed changes to the post-shutdown augmented ERO responding to the OSC.

Page 37 of 51 Table 4.5-3 Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented ERO Positions Positionsl Operations Support Center OSC Manaqer OSC Manager Assistant OSC Manager OSC Systems Engineers OSC RP Coordinator OSC RP Coordinator OSC Communicator OSC Team Briefer/Debriefer and RP Briefer/Debriefer2 Rad Data Technician Rad Data Technician On-call Personnel (Electrical, I&C, On-call Personnel (EIectrical, Mechanica! Mechanical Maintenance, RP, Chemistry) Maintenance, RP, Chemistry) - Reduced numbers Pool Personnel (Electrical, l&C, Available to respond on an as-needed basis Mechanical Maintenance, RP, Chemistry, Operations) 1 A dash (-) indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan. 2 The OSC Team Briefer/Debriefer and the RP Briefer/Debriefer are two separate positions. The OSC is located on the third floor of the Containment Access Facility. Following permanent cessation of power operations and permanent remova! of fuel from the reactor vessel, the OSC will continue to be located on the third floor of the Containment Access Facility. The proposed changes to the DBNPS Emergency Plan do not involve any physical modifications to, or layout and configuration changes in, the OSC. The OSC Manager is responsible for ensuring adequate staffing of the OSC to support the emergency, working with the Emergency Plant Manager to set priorities for the OSC, and directing the activities of the OSC to support the emergency response. lf at any time the OSC Manager determines additional manpower is necessary to accomplish the mission of the OSC, the OSC Manager wil! arrange for additional personnel to support the emergency response functions of the OSC. ln the permanently shutdown and defueled condition, the primary functions of the OSC will remain dispatching of, and accounting for, Repair and Corrective Action Teams. The OSC Manager is responsible for ensuring adequate staffing of the OSC and continuously evaluating the need for resources. The OSC Manager can call in additional assistance, if necessary. OSC resources will continue to be positions with specific training and qualification requirements for personnel in accordance with the site training program.

Page 38 of 51 The following OSC positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel: o Assistant OSC Manager

   . OSC System Engineers
   . OSC Communicator o   RP Briefer/Debriefer o   OSC Team Briefer/Debriefer
   . Reduced numbers of on-call personnel (Mechanical Maintenance, l&C, Electrical) ln the permanently shutdown and defueled condition, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The primary events of concern in the post-shutdown and defueled condition will be a waste gas decay tank rupture, a FHA, a loss of SFP cooling or water inventory, and external events. Events involving a loss of SFP cooling or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.54(hhx2). These strategies will continue to be maintained as they are part of License Condition 2.C(8) of Renewed Operating License NPF-3. The OSC staff is not relied upon to implement SFP inventory activities.

Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC in a permanently shutdown and defueled condition. Although ERO activation and response time requirements will be unchanged, the elimination of credible accidents involving an operating reactor provides additionaltime to plan and execute assessment and mitigation actions. The proposed ERO changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency or provide information to offsite authorities in a timely manner. Therefore, the Assistant OSC Manager, OSC System Engineers, RP Briefer/Debriefer, and OSC Team Briefer/Debriefer positions can be eliminated without placing an undue burden on the remaining ERO positions in the OSC and without increasing the risk to public health and safety. The proposed staffing changes eliminate one (1) augmenting Mechanical Maintenance Technician, the augmenting l&C Technicians, and one (1) augmenting Electrical Maintenance Technician. These positions are included in DBNPS Table 5-18 as augmenting responders. The elimination of these augmented ERO positions was previously described in Section 4.4.5, which evaluated the Major FunctionalArea of Plant System Engineering, Repair and Mitigative Actions. The proposed augmented ERO staffing continues to address the risks to public health and safety, comply with the DBNPS Emergency Plan, site commitments, and applicable regulations.

Page 39 of 52 Attachment 4 contains an analysis of the OSC augmented ERO positions proposed for elimination and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent remova! of fuel from the reactor vessel. The analysis evaluates and dispositions each ERO task as being reassigned or eliminated, as appropriate. Based on the analysis, given the elimination of credible accidents involving an operating reactor, the proposed post-shutdown augmented ERO can continue to satisfactorily perform their existing Emergency Plan responsibilities, as well as any transferred responsibilities. 4.5.2.3 Emerqency Operations Facilitv Ausmentinq Positions DBNPS Emergency Plan Section 5.5.2, "Emergency Operations Facility (EOF) Organization," describes the DBNPS ERO, their key positions and associated responsibilities, including augmented ERO positions that respond to the EOF. Table 4.5-4 identifies those augmented ERO positions that respond to the EOF following an emergency declaration and the proposed changes to the post-shutdown augmented ERO responding to the EOF. Table 4.54 Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented ERO Positions Positionsl Emergency Operations Facility Emergency Director Emergency Director Emergency Offsite Manager Emergency Offsite Manager Emergency Director Advisor EOF Operations Advisor Dose Assessment Coordinator Dose Assessment Coordinator RTL Coordinator RTL Coordinator RMT Coordinator RMT Coordinator Dose Assessor (2) Dose Assessor (1) DBAB RMTs DBAB RMTs Field RMTs Field RMTs Emergency Facility Services Manager2 Emergency Planning Advisor Emergency Planning Advisor Log & Status Board Keepers State/County Comm u nicator State/County Communicator Resource Coordinator (includ ing Warehouse poo! personnel)

Page 40 of 51 Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented ERO Positions Positionsl NRC Liaison Assembly Area Coordinator (including Maintenance Services personnel) Technical Liaison - EOF Communicator Technical Liaison - EOF Communicator Technical Liaisons (Ohio, Ottawa County, Technical Liaisons (Ohio, Ottawa County, Lucas Countv) Lucas County) 1 A dash (--) indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan. 2 Position is located in the TSC, but the position reports to the Emergency Offsite Manager located in the EOF The EOF functions to maintain overall management of the emergency response resources; evaluate, coordinate, and communicate emergency response activities with federal, state, and county emergency response organizations, evaluate offsite radiological condition, and make recommendations to offsite agencies regarding protective actions. Federal, state, and county representatives are provided space and communications at the EOF, and staff this facility at an Alert or higher classification. The EOF is located offsite near Lindsey, Ohio. Following permanent cessation of power operations, the EOF will continue to be located at its current location near Lindsey, Ohio. The proposed changes to the DBNPS Emergency Plan do not involve any physical modifications to, or layout and configuration changes in, the EOF. The EOF maintains extensive communications capability with all DBNPS ERFs and direct links are established between the EOF, the state and county emergency operation centers (EOCs), and the JIC to provide up-to-date emergency status reports. The proposed changes to the DBNPS Emergency Plan do not involve changes to the ability of offsite authorities to report to the EOF, and as a result, do not impact the ability of the offsite authorities to mobilize to, or operate from, the EOF. When activated, the Emergency Director reports to the EOF and directs the activities of the augmented ERO throughout the emergency and until the recovery activities have been terminated. The Emergency Director, or a designated alternate, issues periodic status reports of the event to offsite representatives located in the EOF. The Technical Liaison - EOF Communicator will provide and interpret plant information to the offsite representatives in the EOF. Additionally, Technical Liaisons are dispatched to the state and county EOCs when requested and appropriate, or generally, during an Alert or higher declaration to act as a liaison with the plant technical staff so the magnitude of the emergency can be more clearly conveyed to the state and county staffs in their respective EOCs. The proposed ERO changes do not reduce the ability of DBNPS to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided. As a result, the proposed changes do not impact the ability of DBNPS to communicate with the offsite response organizations.

Page 41 of 51 Centralized coordination of offsite radiological assessments is necessary to ensure that the data and its interpretation are reviewed by the DBNPS and offsite response organizations with monitoring and assessment responsibilities. The number and type of organizations performing this effort vary with time and follow emergency declarations and offsite notification. lnitially, plant emergency response personnel are performing this function, and they are directed from, and their results evaluated, at the Radiological Testing Laboratory (RTL). The RTL is a facility located near the TSC whose purpose is to equip and dispatch radiological monitoring teams (RMTs); and for the receipt, counting, and disposition of potentially contaminated environmenta! samples. The RTL reports to the Dose Assessment Coordinator in the EOF. State and federal response agencies would augment plant assessment efforts. The proposed changes to the EOF staff do not impact the capability to assess and monitor actua! or potential offsite consequences of a radiological emergency. Appropriate assessment and mitigation are within the capabilities of the proposed EOF staff provided in Table 4.5-4. DBNPS will continue to maintain the capability to display plant and meteorological data in the EOF, maintain offsite monitoring equipment at the RTL, and maintain the current dose assessment capabilities at the EOF. The proposed staffing changes includes the elimination of the NRC Liaison position. The primary duty of the NRC Liaison is to establish and maintain communication with the NRC. The Technical Liaison - EOF Communicator, located in the EOF, is assigned these duties in the post-shutdown emergency plan. !n addition to the NRC Liaison, the following EOF positions are proposed for elimination following the docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel: o Emergency Director Advisor o EOF Operations Advisor o Emergency Facility Services Manager

    . Log and Status Board Keepers o  Resource Coordinator (including Warehouse pool personnel) o  Assembly Area Coordinator (including Maintenance Services personnel)

The proposed elimination of the EOF staffing listed above does not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the EOF and without increasing the risk to public health and safety. The EOF will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions proposed for elimination will be reassigned to remaining positions. The proposed augmented ERO staff will continue to address the risks to public health and safety and comply with applicable regulations. The proposed changes to the ERO staffing

Page 42 of 51 in the EOF do not impact the ability of the state and county response organizations to effectively implement their Federal Emergency Management Agency (FEMA) approved radiological emergency plans. Additional discussion of the potential impact on offsite response organizations is included in Section 4.6. Attachment 4 contains an analysis of the EOF augmented ERO positions proposed for elimination and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent remova! of fuel from the reactor vessel. The analysis evaluates and dispositions each ERO task as being reassigned or eliminated, as appropriate. Based on the analysis, given the elimination of credible accidents involving an operating reactor, the proposed post-shutdown augmented ERO can continue to satisfactorily perform their existing Emergency Plan responsibilities as well as any transferred responsibilities. 4.5.2.4 Joint lnformation Center Auqmentinq Positions DBNPS Emergency Plan Section 5.6, "Joint Information Center (JlC),'and Figure 5-2, Page 10, provides the augmented ERO positions that respond to the JlC. Table 4.5-5 identifies those augmented ERO positions that respond to the JIC following an emergency declaration and the proposed changes to the post-shutdown augmented ERO responding to the JlC. Table 4.5-5 Current DBNPS Augmented ERO Proposed Post-Shutdown Augmented ERO Positions Positionsl Joint !nformation Center Company Spokesperson Company Spokesperson JIC Manager JIC Manager Public Affairs Duty Officer Security Security JIC Writer News Statement Coordinator JIC Communicator Public Relations Communicator2 Aud ioA/isual Coordinator Technical Briefer Technical Briefer Public lnquiry Hotline Operator Public lnquiry Hotline Operator Media Assistant (2) Media Assistant (2) 1 A dash (-) indicates the position is proposed for elimination upon implementation of the Post-shutdown Emergency Plan. 2 Ihe position is located in the EOF, but reports to the JIC Manager located in the JlC.

Page 43 of 51 The DBNPS JIC is in a facility located outside of the 1O-mile EPZ. The JIC provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the public. Media monitoring and rumor control are also accomplished at the JlC, allowing company and state representatives to address incorrect information or rumors. Responses to media telephone inquiries are also addressed at the JlC. The JIC meets the intent of the guidance in Planning Standard G of NUREG-0654. Following permanent cessation of operations and permanent removal of fuel from the reactor vessel, the JIC will continue to be located at a facility outside of the 10-mile EPZ. The proposed changes to the DBNPS Emergency Plan do not involve any physical modifications to, or layouUconfiguration changes in, the JlC. The following JIC positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel: o Public Affairs Duty Officer o JIC Writer o News Statement Coordinator o Public Relations Communicator

   . JIC Communicator o   AudioA/isual Coordinator ln the permanently shutdown and defueled condition, media briefings and rumor control will continue to be conducted regularly during an emergency to provide accurate and timely information to the public. The proposed JIC staffing changes described above do not impact the capabilities of the augmented ERO staff to provide emergency event information. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the JIC and without increasing the risk to public health and safety. Functional responsibilities of the positions proposed for elimination will be reassigned to remaining positions. contains an analysis of the JIC augmented ERO positions proposed for elimination and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The analysis evaluates and dispositions each ERO task as being reassigned or eliminated, as appropriate. Based on the analysis, given the elimination of credible accidents involving an operating reactor, the proposed post-shutdown augmented ERO can continue to satisfactorily perform their existing Emergency Plan responsibilities as well as any transferred responsibilities.

Page 44 of 51 4.6 Assessment of Prooosed Staffino Cha on Offsite Resoonse Oroanization lnterfaces FENOC evaluated the proposed DBNPS Emergency Plan ERO staffing changes for impacts on the ability of the State and County response organizations to implement their FEMA-approved rad iological emergency plans. The evaluation follows. Due to the location of DBNPS, the planning and responsibilities at the state and local levels involve coordination with the State of Ohio, and Ottawa and Lucas Counties. DBNPS Emergency Plan Section 3.2, "Emergency Organizations," describe the DBNPS requirements to notify the State and Counties of emergencies. The proposed changes to the DBNPS Emergency Plan do not involve changes to these notification requirements, and as a result, DBNPS maintains the ability to notify the appropriate offsite authorities of emergencies. DBNPS Emergency Plan Section 7.6, "Communications Systems," describes the communications network maintained between DBNPS, state, and local organizations as a means of promptly notifying and maintaining communications with appropriate authorities. lncluded in the communications network is a dedicated 4-way phone system. The 4-way phone system permits DBNPS personnel in the Control Room and the EOF to communicate with the State and County Warning Points and EOCs, the Ohio Highway Patrol Office, and the Lucas County and Ottawa County Sheriffs dispatcher offices during emergency situations. The proposed changes to the DBNPS Emergency Plan do not involve changes to the communications network, and as a result, do not impact the ability of DBNPS to notify and initiate coordination with the offsite authorities regarding emergency events. DBNPS dispatches technical liaisons to the State and County EOCs when requested, or generally, at an Alert or higher declaration, to aid in the EOC's staff in understanding of the event. These positions are retained in the post-shutdown augmented ERO. Therefore, DBNPS maintains the ability to aid offsite officials with respect to emergency events. ln summary, no coordination or communication impediments, with the offsite response organizations were identified by the proposed changes to the DBNPS ERO. As a result, there should no impact on the ability of the State and County response organizations to implement their FEMA-approved radiological emergency plans. 4.7 Validation and Traininq To validate the results of the proposed changes to the ERO described within this amendment request, FENOC will perform a drill to confirm the ability of the Post Shutdown on-shift and augmented emergency response organization to perform the necessary functions of each emergency response facility and to utilize the post-shutdown procedures being developed, depicting the revised assignment of duties. The drill will evaluate the ability to accomplish the stated mission of each ERF and ensure that the planning standard functions are preserved with no degradation in time sensitive

Page 45of51 activities or in the ability to communicate with offsite response organizations. State and local response organizations will be provided the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities. This is a regulatory commitment and is listed in Attachment 5. Training will be developed and be in place prior to performing the post-shutdown ERO validation drill. The drill scenario will include SFP events and will be designed to test the major elements of the DBNPS Post-Shutdown Emergency Plan. Major elements to be tested will include communications and coordination with offsite response organizations, including the JlC. lmplementing procedures will be revised to address the permanently shutdown and defueled conditions. These post-shutdown procedures will be available in draft form to support the post-shutdown ERO staff training and the conduct of the drills. Final implementation of the procedures will occur concurrent with implementation of the requested DBNPS Post-Shutdown Emergency Plan changes. ln addition, other training drills will be conducted to train post-shutdown ERO members These drills may not involve every ERF or state or local organization participation. However, every ERO member will participate in at least one training drill. 4.8 Conclusion As described in Section 4, FENOC evaluated the proposed changes in the DBNPS on-shift staff. Additionally, a proposed post-shutdown on-shift staffing analysis was performed to validate the ability of the proposed post-shutdown on-shift staff to implement emergency plan functions in conjunction with the postulated accidents that will be applicable in the permanently shutdown and defueled condition. An evaluation of the proposed augmented ERO staffing was performed to analyze the transfer of tasks from those positions proposed for elimination to remaining augmented ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor. Functional responsibilities of the ERO positions proposed to be eliminated are either being reassigned to remaining ERO positions or eliminated if no longer applicable in the permanently defueled condition. The proposed post-shutdown ERO changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency and the ability to promptly implement SFP mitigation actions. Appropriate assessment and mitigating actions are within the capabilities of the reduced ERO staff. Therefore, the proposed ERO will continue to address the risks to public health and safety, and comply with the DBNPS Emergency Plan, and applicable regulations.

Page 46 of 51

5.0 REGULATORY EVALUATION

5.1 ApplicableRequlatorvRequirements/Criteria Reoulations The specific standards for establishing an onsite emergency organization to respond to emergency events is contained in 10 CFR 50.47(b) and 10 CFR Part 50, Appendix E, Section lV.A. 10 CFR 50.47(bX1) states 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. 10 CFR 50.47(b)(2) states On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initialfacility 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. 10 CFR Part 50, Appendix E, Section lV.A.1 states that emergency plans must contain A description of the norma! plant operating organization. 10 CFR Part 50, Appendix E, Section lV.A.2: states that emergency plans must contain: A description of the onsite emergency response organization with a detailed discussion of: a Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency; a Plant staff emergency assignments; a Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

Page 47 of 51 10 CFR Part 50, Appendix E, Section lV.A.g states that licensees perform [A] detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. Guidance NRC Regulatory Guide 1.101, "Emergency Response Planning and Preparedness for Nuclear Power Reactors," Revision 4, July 2003, states in part: The criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," (November 1980) are methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans. These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness. NUREG-0654, Section ll, "Planning Standards and Evaluation Criteria," Evaluation Criteria !1.B.1 and Il.B.5 address the 10 CFR 50.47(bX2) planning standard. Evaluation Criterion ll.B.1 specifies the onsite emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal shift complement. Evaluation Criterion ll.B.5 states in part that: 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 on-site 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. NSIR/DPR-ISG-O1, "lnterim Staff Guidance - Emergency Planning for Nuclear Power Plants," Revision 0 (Reference 6) provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI 10-05 (Reference 2) is an acceptable methodology for performing the staffing analysis. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.5a(q)(5)

Page 48 of 51 NRC Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," Revision 1, July 2016, describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.5a(q). ln Section 2.a.(2), the NRC encourages licensees to arrange a conference callwith the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for changes in ERO staffing that eliminates key ERO positions. Regulatory lssue Summary 2005-02, "Clarifying the Process for Making Emergency Plan ChangS," Revision 1, was issued by the NRC to clarify the meaning of "decrease in effectiveness" and the process for making changes to emergency plans, and to provide some examples of changes that are considered to be a decrease in effectiveness. Conclusion The proposed changes to the DBNPS Emergency Plan do not affect compliance with these regulations or guidance and, as a result, the standards and requirements would continue to be met. 5.2 Precedent The requested changes to the on-shift staffing and augmented ERO staffing are similar in nature to the post-shutdown changes approved by the NRC for Vermont Yankee Nuclear Power Station (Accession No. ML14346A065) (Reference 7), Ft. Calhoun Station (Accession No. ML17123A348) (Reference 8), and Oyster Creek Nuclear Generating Station (Accession No. M117356A213) (Reference 9). 5.3 No Sionificant H s Consideration The proposed amendment would revise the Davis-Besse Nuclear Power Station (DBNPS) Emergency Plan on-shift and augmented Emergency Response Organization (ERO) staffing in order to support the planned permanent cessation of power operations and permanent defueling of DBNPS. Specifically, the proposed changes in this license amendment request would eliminate the on-shift positions not needed for the safe storage of spent fuel in the spent fuel pool (SFP) during the initial decommissioning period and eliminate ERO positions not necessary to effectively respond to remaining credible accidents. The proposed changes to the on-shift and augmented ERO staffing are commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facility. FirstEnergy Nuclear Operating Company (FENOC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of amendment," as discussed below:

Page 49 of 51 1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated? Response: No. The proposed changes to the DBNPS Emergency Plan do not impact the function of plant structures, systems, or components (SSCs). The proposed changes do not involve the modification of any plant equipment or affect plant operation. The proposed changes do not affect accident initiators or precursors, nor does it alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and augmented ERO to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently shutdown and defueled condition. The proposed changes only remove positions that will no longer be credited in the DBNPS Emergency Plan. Therefore, the proposed amendment does 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 reduce the number of on-shift and augmented ERO positions commensurate with the hazards associated with a permanently shutdown and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also, the proposed changes do not result in a change to the way that the equipment or facility is operated so that no new accident initiators are created. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any 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 (fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes do not adversely affect existing plant safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes. The proposed changes are associated with the DBNPS Emergency Plan and do not impact operation of the plant or its response to transients or accidents. The change does not affect

Page 50 of 51 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 the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes. The revised DBNPS Emergency Plan will continue to provide the necessary response staff with the proposed changes. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety. Based on the above, FENOC 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. 5.4 Conclusion ln conclusion, based on the considerations discussed above, FENOC concludes that (1) there is reasonable assurance that the health and safety of the public wil! not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's 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.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed changes are applicable to emergency planning standards for DBNPS involving on-shift and augmented ERO staffing to support the planned permanent cessation of operations and permanent defueling of the facility. The proposed changes do not reduce the capability to meet the emergency planning standards established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed amendment is confined to changes to recordkeeping, reporting, or administrative procedures or requirements; changes to the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager; or changes to the format of the license or permit or otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. Accordingly, the proposed changes meet 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.

Page 51 of51

7.0 REFERENCES

1 NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiologica! Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, published November 1980. 2 NEI 10-05, Rev. 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" (Accession No. ML111751698). 3 FENOC Letter to NRC, "License Amendment Request - Proposed Changes to Technical Specifications Sections 1.1 "Definitions," and 5.0 "Administrative Controls" for a Permanently Defueled Condition," dated October 22,2018 (Accession No. ML18295A289). 4 FENOC Letter to NRC, "Request for Approval of Certified Fuel Handler Training Program," dated August 15,2018 (Accession No. ML18227A019). 5 Federal Register Volume 76, Number 226, Wednesday, November 23,2011, Rules and Regulations, "Enhancements to Emergency Preparedness Regulations; Final Rule." 6 NSIR/DPR-lSG-01, "lnterim Staff Guidance - Emergency Planning for Nuclear Power Plants," Revision 0, November 2011 (Accession No. ML113010523). 7 Letter, USNRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - lssuance of Amendment to Renewed Facility Operating License Re: Changes to the Emergency Plan (TAC No. MF3668)," dated February 4,2015 (Accession No. ML14346A065) 8 Letter, USNRC to Omaha Public Power District, "Fort Calhoun Station - Unit 1 - lssuance of Amendment Re: Revise Emergency Plan to Address the Permanently Defueled Condition (CAC No. MF8326)," dated July 27,2017 (Accession No. ML17123A348) I Letter, USNRC to Exelon Generation Company, LLC, "Oyster Creek Nuclear Generating Station - lssuance of Amendment Re: Changes to the Emergency Plan for Permanently Defueled Condition (CAC No. MFg352; EPID L-2017-LLA-0177), dated March 7,2018, (Accession No. M117356A213)

Attachment 1 Tabular Summary of Proposed Changes to the DBNPS Emergency Plan, Revision 33 (61 Pages Follow)

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Cover page/Header Davis-Besse Nuclear Power Station Davis-Besse Nuclear Power Station Reflect the change to post shutdown. Emergency Plan Post-Shutdown Emergency Plan The'Revision 33' to'Revision TBD' and'Emergency Plan' to Revision 33 Revision TBD "Post-Shutdown Emergency Plan" changes are made globally and are not specifically identified in the remainder of this document. Foreword, paragraph Revision 33 of the Emergency Plan Revision TBD of the Post-Shutdown This change will be submitted for NRC approval. 3 meets the requirements of 10 CFR Emergency Plan meets the 50.5a(q). Changes made in Revision requirements of 10 CFR 50.54(q). 33 of the Emergency Plan do not Changes made in Revision TBD do decrease the effectiveness. not decrease the effectiveness. The Plan has been revised in accordance with NRC Safety Evaluation [IBD]. Foreword, paragraph The issuance and control of this The issuance and control of this Editorial change - titles. 4 Emergency Plan and activities Post-Shutdown Emergency Plan and Deleted position titles and change to General Plant Manager associated with Emergency aclivities associated with Emergency Response at the Davis-Besse Response at the Davis-Besse Nuclear Power Station are the Nuclear Power Station are the responsibility of the Site Vice responsibility of the General Plant President, DB Nuclear. Additions, Manager. Additions, deletions, or deletions, or modifications to the modifications to the Post-Shutdown Emergency Plan shall be approved Emergency Plan shall be approved by the Emergency Response by the Emergency Response Manager, the Director, Site Manager and the General Plant Performance lmprovement, and the Manager. lt is intended that this General Plant Manager. lt is Post-Shutdown Emergency Plan and intended that this Emergency Plan the Emergency Plan Procedures be and the Emerqency Plan Procedures fully compatible with the applicable 1

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section be fully compatible with the requirements for quality assurance applicable requirements for quality set forth in the FENOC Nuclear assurance set forth in the FENOC Assurance Program Manual. Nuclear Assurance Program Manual. Foreword, signatures Director, Site Performance Deleted. Reflect the change to post shutdown organization. lmprovement These position titles changed to the General Plant Manager Site Vice President, DB Nuclear Summary of Plan List of changes made for Rev 33 Full revision to address Reflect the change to Post-Shutdown Emergenry Plan Changes implementation of the Post-Shutdown Emergency Plan. No List not provided for simplicity revision bars are used to identify the changes. The changes to the on-shift and augmented Emergency Response Organization stafiing support the permanent cessation of power operations of the Davis-Besse Nuclear Power Station and the permanent removal of fuel from the reactor vessel. List of Rev 33 changes deleted. Table of Contents Sections, List of Tables, List of Sections, List of Tables, List of Editorial - renumbered due to changes reflecting the Post-Figures, and page numbering Figures, and page numbering Shutdown Emergenry Plan Table of Contents, 4.4 EMERGENCY ACTION LEVELS EMERGENCY ACTION LEVELS Fission Product Baniers are no longer applicable in the (EALs) and Fission Product Barriers (EALs) permanently shutdown and defueled condition. (FPBs) 2

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Table of Contents, Barrier Abbreviation Codes Deleted Fission Product Barriers are no longer applicable in the 4.4.1 permanently shutdown and defueled condition. Table of Contents, Fission Product Baniers (FPBs) Deleted Fission Product Baniers are no longer applicable in the 4.4.2 Recognition Categories Codes permanently shutdown and defueled condition. Table of Contents, Operation Mode Applicability Deleted Operation Modes are no longer applicable in the permanently 4.4.3 shutdown and defueled condition. Table of Contents, Plant Management and Facility Management and The term "plant" is changed to Tacility." This is an administrative 5.1.1 Administrative Organization Administrative Organization change that reflects DBNPS will be permanently shutdown and defueled. The term "facility' is a more appropriate description of a site that is undergoing decommissioning. The "plant'to "facility change is made globally and is not specifically identified in the remainder of this document. Table of Contents, Emergency Direc{or Advisor Deleted The position does not exist in the Post-Shutdown ERO. 5.2.5 Table of Contents, Unit Supervisor Deleted The title "Unit Supervisor will not exist in the post-shutdown on-5.3.2 shift staff. Table of Contents, Shift Engineer (Shift Technical Deleted. The Shift Engineer (Shift Technical Advisor) position will not exist 5.3.3 Advisor) in the post shutdown on-shift staff. Table of Contents, Davis-Besse Nuclear Power Station Davis-Besse Nuclear Power Station Reflect the change to post shutdown. Appendix F (DBNPS) ERO On-Shift Staffing (DBNPS) ERO Post-Shutdown On-Analysis Report Shift Staffing Analysis Report 1.3, Alternate An area within the Lindsey An area within the Lindsey Reflect the change to post shutdown. Technical Suoport Emergency Response Facility, which Emergency Response Facility, which ln the permanently shutdown and defueled condition, the spent Center (ATSC) has the capability to display and has the capability to display and fuel pool operation is the focus of ATSC personnel. transmit plant status information to transmit facility information to individuals who are knowledoeable individuals who are knowledoeable 3

Emergency PIan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section of, and responsible for engineering of, and responsible for engineering and management support of reactor and management support of SFP operations in the event of an operations in the event of an emergency situation. emergency situation. 1.11, CONTAINMENT The procedurally defined actions Deleted The defined term is never used in the Emergency Plan. CLOSURE taken to secure containment and its Deletion of this definition will result in a renumbering of the associated structures, systems, and definitions listed in Section 1.0, "Definitions.' The renumbering is components as a functional barrier considered an administrative activity and will not be described to fission product release under within the reminder of Section 1.0. existing plant conditions. 1.21, Emeroencv Engineered safety features system Deleted Reflect the change to post shutdown. Core Coolino Svstem comprised of the Low Pressure ECCS is no longer required in the permanently shutdown and lnjection, High Pressure lnjection, defueled condition. and Core Flood Systems. 1.31, FAULTED The term applied to a steam Deleted Reflect the change to post shutdown. generator that has a steam leak on ln the permanently shutdown and defueled condition the steam the secondary side of sufficient size generator is not operating. to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. 1.33, FISStON A pre-determined, site-specifi c, Deleted Reflecl the change to post shutdown. PRODUCT BARRIER observable threshold indicating the Fission Product Baniers are no longer applicable in the THRESHOLD loss or potential loss of a fission permanently shutdown and defueled condition. product barrier. 1.44, INDEPENDENT INDEPENDENT FUEL STORAGE INDEPENDENT SPENT FUEL Editorial Change - correct title. FUEL STORAGE INSTALLATION (ISFSI) STORAGE INSTALLATION (ISFSI) FACILITY 4

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 1.76, RCS INTACT The RCS should be considered Deleted. The reactor, Reactor Coolant System (RCS) is no longer in intact when the RCS pressure operation and has no funclion related to the storage of the boundary is in its normal condition irradiated fuel and can be removed from the emergency plan for the cold shutdown mode of operation (e.9., no freeze seals or nozzle dams). 1.78, REFUELING The reactor refueling canal, spent Deleted. Reflect the change to post shutdown. PATHWAY fuel pool and fuel transfer canal ln the permanently shutdown and defueled condition the reactor comprise the REFUELING will not be refueled and reference to the refueling pathway is not PATHWAY. necessary. 1.81, RUPTURED The condition of a steam generator Deleted. Reflect the change to post shutdown. in which primary-to-secondary ln the permanently shutdown and defueled condition the steam leakage is of sufficient magnitude to generator is not operating. require a safety injection. 1.82, Safetv A computer system that acquires A computer system that acquires Reflect the change to post shutdown. Parameter Displav and displays plant data. This and displays facility data. This ln the permanently shutdown and defueled condition ERDS ls no Svstem (SPDS) system provides data to Operator system provides data to Operator longer required. Aids and the Emergency Response Aids. Data System (ERDS). 1.83, SAFETY A system required for safe plant Deleted. Reflect the change to post shutdown. SYSTEM operation, cooling down the plant ln the permanently shutdown and defueled condition these are no and/or placing it in the cold longer required. 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 5

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Ghange Section 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, Shift Manaqeis A facility that is located within the A facility that is located within the Revised to allow for flexibility in the location of the Emergency Office Control Room envelope and is used Control Room envelope and may be Assistant Plant Manager. by the Emergency Assistant Plant used by the Emergency Assistant Manager during emergency Plant Manager during emergency conditions to observe and provide conditions to observe and provide guidance to the Shift Manager for guidance to the Shift Manager for direction and control of in-plant direction and control of facility activities. activities. Table 1-1, AFW - Auxiliary Feed Water Deleted. Reflecl the change to post shutdown. ACRONYMS ln the permanently shutdown and defueled condition these APRM - Average Power Range Meter acronyms are no longer required. ATWS - Anticipated Transient Removed acronyms not used in the Emergency Plan. Without Scram BWR - Boiling Water Reactor 6

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section BWST - Borated Water Storage Tank CCW- Component Cooling Water CRA - Control Rod Assembly CSF - Critical Safety Function CSFST - Critical Safety Function Status Tree CTMT/CNMT - Containment DBTC - Davis-Besse Training Center DHR - Decay Heat Removal ECCS - Emergency Core Cooling System EOP - Emergency Operating Procedure EPG - Emergency Procedure Guideline EPRI - Electric Power Research lnstitute ERG - Emergency Response Guideline ESF - Engineered Safety Feature ESW - Emergency Service Water 7

Emergency PIan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section FAA - FederalAviation Administration HPI - High Pressure lnjection HPCI - High Pressure Coolant lnjection HPSI - High Pressure Safety lnjection IPEEE - lndividual Plant Examination of External Events (Generic Letter 88-20) ITS - lmproved Technical Specifications LER - Licensee Event Report LOCA - Loss of Coolant Accident LPI - Low Pressure lnjeclion LPSI - Low Pressure Safety lnjeclion LPZ - Low Population Zone LWR - Light Water Reactor MFW- Main Feed Water (pump) MSIV - Main Steam lsolation Valve MSL - Main Steam Line MSSV - Main Steam Safety Valve I

Emergency Plan After (Pending Revision Number) Reason for Change Before (Rev. 33) Section MU - Makeup MU-HPl - Makeup High Pressure lnjection NESP - National Environmental Studies Project NORAD - North American Aerospace Defense Command NSSS - Nuclear Steam Supply System NUMARC - Nuclear Management and Resources Council OTSG/SG - Steam Generator PAF - Primary Access Facility POAH - Point of Adding Heat PORV- Power Operated Relief Valve PRA/PSA - Probabilistic Risk AssessmenUProbabilistic Safety Assessment PWR - Pressurized Water Reactor RCC - Reactor Control Console RCDT - Reactor Coolant Drain Tank RCIC - Reactor Core lsolation Cooling 9

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section RCS - Reactor Coolant System RETS - Radiological Effluent Technical Specifi cations RPS - Reactor Protection System RPV - Reactor Pressure Vessel RO - Reactor Operator RVLIS - Reactor Vessel Level lndicating System RWCU - ReactorWater Cleanup SAM - Severe Accident Management SBGTS - Stand-By Gas Treatment System SBO - Station Blackout SG - Steam Generator Sl - Safety lnjection SRO - Senior Reactor Operator STA - Shift TechnicalAdvisor TOAF - Top of Active Fuel VPF - Visitor Processing Center Table 1-1, Added: Reflect the change to post shutdown. ACRONYMS CFH - Certified Fuel Handler On-shift staff will include Certified Fuel Handlers (CFHs) and Non-Certified Operators (NCOs). 10

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section NCO - Non-Certified Operator SFP - Spent Fuel Pool 2.1, Site Description, DBNPS employs a pressurized light DBNPS formerly employed a Reflect the permanently shutdown and defueled condition. 2nd paragraph water reactor steam supply system pressurized light water reaclor furnished by the Babcock & Wilcox steam supply system fumished by Co. (now AREVA NP) to generate the Babcock & Wilcox Co. (now approximately 930 MWe. The AREVA NP) to generate reactor design core power is 2817 approximately 930 MWe. The MWt. reactor design core power was2817 MWt. The reac{or permanently ceased power operations on [DATE] and was permanently defueled on [DATE]. Spent Fuel is stored in the Spent Fuel Pool (SFP) and the lndependent Spent Fuel Storage lnstallation (lSFSl). 2.6.7 Other offsite organizations, not Other offsite organizations, not Reflect the change to post shutdown. within the immediate area, may also within the immediate area, may also Davis-Besse will no longer be an operating plant and support be requested to offer technical be requested to offer technical from INPO is not expected. assistance (i.e., lnstitute of Nuclear assistance (i.e., AREVA NP, Power Operations, AREVA NP, Bechtel, etc.). Bechtel, etc.). Table 2-1, Plant Operation Control SFP Operation Control Reflec{ the change from reaclor control to SFP control in the FUNCTIONAL permanently shutdown and defueled condition. INTERRELATIONSHI PS OF RESPONSE ORGANIZATIONS 11

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 3.2, Emerqencv lf the Shift Manager cannot assume lf the Shift Manager cannot assume The Shift Engineer (Shift TechnicalAdvisor) position will not exist Orqanizations, 3'd these duties, authority is delegated these duties, authority is delegated in the post shutdown on-shift staff. paragraph, 3'd to the Unit Supervisor or Shift to another qualified member of the The title "Unit Supervisof will not exist in the post-shutdown on-sentence Engineer (Shift Technical Advisor) in on-shift staff. shift staff. that order. 3.2, Emerqencv The Emergency Plant Manager or The Emergenry Plant Manager or The Emergency Assistant Plant Manager and the Emergency Orqanizations, 3rd Emergency Assistant Plant Manager Emergency Assistant Plant Manager Plant Manager may respond to the TSC. paragraph, 4th and 5h may assume the Emergency may assume the Emergency sentences Director position upon arrival in the Director position upon arrival in the Control Room. The Emergency Control Room or TSC. Plant Manager may also assume the Emergency Director duties from the Technical Support Center. 3.2, Emeroencv The operating shift crew is The on-shift crew is responsible for Reflect the permanently shutdown and defueled condition. Q@,4'n responsible for implementing implementing emergency paragraph emergency procedures in procedures in accordance with accordance with assigned response assigned response functions. functions. Emergency response Emergency response func{ions are functions are also assigned to off- also assigned to off-shift facility staff shift plant staff personnel who can personnel who can be rapidly alerted be rapidly alerted and mobilized, to and mobilized, to augment or relieve augment or relieve the operating the operating shift personnel of shift personnel of emergency duties. emergency duties. 4.1, Emeroencv An ECL is determined to be met by An ECL is determined to be met by Fission Product Barriers are no longer applicable in the Classification Levels identifying abnormal conditions and identifring abnormal conditions and permanently shutdown and defueled condition. lEE),2nd then comparing them to INITIATING then comparing them to INITIATING paragraph, 2nd CONDITIONS (lCs) through CONDITIONS (lCs) through sentence EMERGENCY ACTION LEVELS EMERGENCY ACTION LEVELS (EAL) and Fission Product Banier 12

Emergency Plan Reason for Ghange Before (Rev.33) After (Pending Revision Number) Section (FPB) threshold values as discussed (EAL) and threshold values as below. discussed below. 4.2, EMERGENCY The 1S-minute criterion commences The 1S-minute criterion commen@s Reflect the permanently shutdown and defueled condition. CLASSIFICATION when plant instrumentation, plant when facility instrumentation, facility alarms, computer displays, or alarms, computer displays, or incoming verbal reports that incoming verbal reports that correspond to an EAL first become correspond to an EAL first become available to any plant operator. available to any facility personnel. 4.3JNlrlArlNG. The INITIATING CONDITION (lC), The INITIATING CONDITION (lC) Fission Product Baniers are no longer applicable in the @qlflQNl!-6L1" EMERGENCY ACTION LEVELS and EMERGENCY ACTION permanently shutdown and defueled condition. paragraph (EALs) and the Fission Product LEVELS (EALs) with their related Banier (FPB) matrix with their basis information are located in related basis information are located Appendix E of the Post-Shutdown in Appendix E of the Emergency Emergency Plan. Plan. 4.3.1, Recoqnition F designates Fission Product Barrier Deleted. Fission Product Baniers are no longer applicable in the Cateqorv Codes Degradation permanently shutdown and defueled condition. 4.4, EMERGENCY EM ERGENCY ACTION LEVELS EMERGENCY ACTION LEVELS Fission Product Baniers are no longer applicable in the ACTION LEVELS (EALs) and Fission Product Barriers (EALs) permanently shutdown and defueled condition. (EALs) and Fission (FPBs) Product Barriers (FPBs) 4.4, EMERGENCY Fission Product Barriers (FPBs) are Deleted. Fission Producl Baniers are no longer applicable in the ACTION LEVELS given unique character identification permanently shutdown and defueled condition. (EALs).3d paraoraoh codes and are further subdivided into Loss and Potential loss categories. Meeting or exceeding one or more FPB can result in

                                                                        't3

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 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 reergnition category. The FPB identification codes are developed as follows: 4.4.1 Barrier Abbreviation Codes Deleted. Fission Product Baniers are no longer applicable in the permanently shutdown and defueled condition. FC designates FUEL CLAD RC designates REACTOR COOLANT CT designates CONTAINMENT 4.4.2 Fission Product Baniers (FPBs) Deleted. Fission Produc{ Baniers are no longer applicable in the Recognition Categories Codes permanently shutdown and defueled condition. A designates RCS or SG Tube Leakage B designates lnadequate Heat Removal C designates CT Radiation / RCS Activity D designates CT lntegrity or Bypass E designates ED Judgment 4.4.2 Fission Product Banier Thresholds Deleted Fission Producl Baniers are no longer applicable in the are listed within each Fission permanently shutdown and defueled condition. 14

Emergency Plan After (Pending Revision Number) Reason for Ghange Before (Rev. 33) Section 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. 4.4.3, Ooeratinq Mode Operating Mode Applicability Deleted. Operating Mode is no longer applicable in the permanently Aoplicabilitv shutdown and defueled condition. For purposes of event classification, the following operating mode applicability defi nitions establish the conditions when the EAL or FPB thresholds represent a threat: Table 4.1 Operating Mode Applicability Deleted Operating Mode is no longer applicable in the permanently shutdown and defueled condition. 4.4.3, Operatino Mode The Operating Mode Applicability Deleted Operating Mode is no longer applicable in the permanently Applicabilitv, 2nd table is based on the Technical shutdown and defueled condition. paragraph Specifications defi nition of Operational Mode. lCs are based on the operating mode that exists at the time the event occuned, prior to any protective system or operator action initiated in response. 4.4.3, Operatinq Mode For events that occur in Cold Deleted Operating Mode is no longer applicable in the permanently Applicabilitv, 3rd Shutdown or Refueling, escalation is shutdown and defueled condition. paragraph via EALs that have Cold Shutdown or Refuelino for mode apolicabilitv. 15

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. ln particular, the FPB threshold values are applicable only to events that initiate in Hot Shutdown or higher. lf 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. 4.4.6, Classifvinq ln some situations, this can be ln some situations, this can be Reflecl the permanently shutdown and defueled condition. .].i@, 1"t readily determined, in other readily determined, in other Reactor coolant sampling is no longer necessary. paragraph,3d situations, further analyses (e.9., situations, further analyses may be sentence coolant radiochemistry sampling) necessary. may be necessary. 5.0, ln planning for emergencies the ln planning for emergencies the Reflect the permanently shutdown and defueled condition. ORGANIZATIONAL availability of the normally present availability of the normally present CONTROL OF operating staff, augmented by on-shifi staff, augmented by support EMERGENCIES, 1SI support from other utility personnel from other utility personnel and paragraph and offsite support agencies, is offsite support agencies, is considered. considered. 5.1, DBNPS Daily operating and engineering Spent fuel storage and engineering Reflect the permanently shutdown and defueled condition. Q@, 1"t activities at DBNPS are under the ac{ivities at DBNPS are under the Editorial change - title. paragraph control of the Vice President - control of the General Plant Nuclear. Manager. 16

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 5.1, DBNPS DBNPS has engineering service DBNPS has engineering service Reflect the permanently shutdown and defueled condition. 9@,2nd contracts with the Nuclear Steam contracts with the Architect- NSSS no longer required. paragraph Supply System (NSSS) supplier and Engineer. the Architect-Engineer. 5.1.1, Plant The General Plant Manager directs The General Plant Manager directs Reflec{ the permanently shutdown and defueled condition Management and and supervises all operating, and supervises all administrative, Administrative administrative, technical and technical and maintenance activities Organization, 1st maintenance activities in connection in connection with the continuous, paragraph with the continuous, efficient and efficient and safe storage of spent safe operation of the DBNPS. fuelthe DBNPS. 5.1.1, Plant To support the General Plant To support the General Plant Reflect the permanently shutdown and defueled condition Management and Manager, an administrative Manager, an administrative Administrative organization has been established. organization has been established. Organization, 2nd Responsibilities have been assigned Responsibilities have been assigned paragraph for the various aspects of station for the various aspects of station operation. activities. 5.1.2, Onshift The Onshift Operations Group The Onshift Operations Group l&C and Chemistry personnelwill not be part of the on-shift staff Operations Group,2nd conforms with ANSI N18.1, and conforms with ANSI N18.1, and post shutdown. paragraph includes both management and includes both management and Dedicated Maintenance personnel will not be part of the on-shift operating personnel. Figure 5-1, operations personnel. Figure 5-1, staff post shutdown. Onshift Emergency Organization, Onshifi Emergency Organization, shows the functional levels. The shows the functional levels. Other Onshift Maintenance Support continuous duty, 24 hours-per-day Organization maintains a 24-hour organizations include Operations, shift rotation. The shift includes Radiation Protection and Security. persons from the Mechanical, Maintenance personnel and the Electrical and lnstrument and various Engineering organizations Control Maintenance Sections. are onsite durinq normal work hours, 17

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section These personnel form the initial Monday through Friday, excluding nucleus staff of the OSC. Other holidays. continuous duly, 24 hours-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, NormalPlant The plant's operating staff meets or The facility's operating staff meets or Reflect the permanently shutdown and defueled condition Shift Staffing, 1't exceeds the requirements of exceeds the requirements of paragraph Technical Specification 5.2.2 and Technical Specifi cation 5.2.2. Technical Requirements Manual 10.2.1. 5.1.3, Normal Plant ln addition, the plant is continuously ln addition, the facility is Chemistry Tester position is not part of the on-shift staff post Shift Staffing, 2nd manned with a minimum shift continuously staffed with a minimum shutdown. paragraph complement consisting of the shift complement consisting of the following: following: 1 Chemistry Tester 1 Radiation Protection Technician 1 Radiation Protection Technician 5 Fire Brigade Members (may have other assignments) 5 Fire Brigade Members (may have other assignments) *Nuclear Security Force

                   *Nuclear Security Force                "safeguards information
                   *safeguards information 18

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 5.1.3, Normal Plant The Shift Manager directs the onshift The Shift Manager directs the onshift The plant will no longer be operating. SFP activities replace Shift Staffing, Srh personnel operating the station and personnel and verifies that their work reactor operation. paragraph verifies that their work is performed is performed according to approved according to approved procedures. procedures. Ultimate authority for Ultimate authority for directing all directing all phases of SFP phases of plant operations always operations always lies with the Shift lies with the Shift Manager. Manager. 5.1.3, Normal Plant A Unit Supervisor, who is assigned Non-Certified Operators, who are The plant will no longer be operating. The referenced systems Shift Staffing, 6th to each shift during power modes, assigned to each shift, assist the will no longer be in service. paragraph assists the Shift Manager by Shift Manager by following his The title "Unit Supervisor will not exist in the post-shutdown on-following his directives in supervising directives in controlling station shift staff. employees engaged in controlling equipment. During an emergency, the operation of the Nuclear Steam the Non-Certified Operators may Supply System, Turbine Generator, also function as emergency and other station equipment. During maintenance personnel or to assist an emergency, the Unit Supervisor fire brigade team members. An may also direct employees to appropriately qualifi ed Non-Certifi ed function as emergency maintenance Operator could assume the role of personnel or to assist fire brigade Shift Manager, including Emergency team members. The Unit Supervisor Director duties, should the Shift assumes the role of Shift Manager, Manager become incapacitated. including Emergency Director duties, should the Shift Manager become incapacitated. 5.1.3, NormalPlant A Shift Engineer (Shift Technical Deleted The Shifi Engineer (Shifi Technical Advisor) is not part of the on-Shift Staffing, 7th Advisor) is normally assigned to the shifl staff post shutdown. paragraph shift to relieve the Shift Manager of administrative responsibilities, such as coordination of maintenance 19

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Ghange Section schedules, establishment of short term objectives for plant operation and review of documentation. ln 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. lf available, the 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 Director if both the Shift Manager and the Unit Supervisor are incapacitated. Under certain circumstances, the Shift Engineer (Shifi Technical Advisor) position may be filled by an onshift Senior Reactor Operator assigned another function, such as Shift Manager. 5.2.1.b.4 Emergency Director Advisor Deleted. The Emergency Director Advisor is not part of the Post-Shutdown ERO. 20

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 5.2.1.c. ln the absence of the Emergency ln the absence of the Emergency The title "Unit Supervisor will not exist in the post-shutdown on-Director, one of the following will Director, one of the following will shift staff. assume the duties and assume the duties and The Shifi Engineer (Shift Technical Advisor) is not part of the on-responsibilities of the Emergency responsibilities of the Emergency shift staff post shutdown. Director: Director:

1. Emergency Plant Manager 1. Emergency Plant Manager

2. Emergency Assistant Plant 2. Emergency Assistant Plant Manager Manager

3. Shift Manager 3. Shift Manager

4. Unit Supervisor 4. Another qualified on-shift individual

5. Shift Engineer (Shift Technical Advisor) 5.2.1.c ln the absence of the Emergency ln the absence of the Emergency The Emergency Assistant Plant Manager may respond to the Plant Manager and the Emergency Plant Manager and the Emergency TSC Director, the Shift Manager may be Director, the Shift Manager may be relieved by the Emergency Assistant relieved by the Emergenry Assistant Plant Manager upon anival in the Plant Manager upon arrival in the Control Room. However, to relieve Control Room or TSC.

the Shift Manager of the Emergency Director's duties, the Emergency Assistant Plant Manager must be in the Control Room. 5.2.3, Emergency The Emergency Plant Manager is The Emergency Plant Manager is The plant will no longer be operating. SFP activities replace Plant Manager the senior individual responsible for the senior individual responsible for reactor operation. the coordination and conduct of all the coordination and conduct of all activities associated with plant activities associated with storage of ooerations. olant assessment. soent fuel in the SFP. facilitv 21

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section emergency classifi cation associated assessment, emergency with plant parameters, and onsite classifi cation associated with facility actions taken to mitigate the parameters, and onsite actions emergency situation. The taken to mitigate the emergency Emergency Plant Manager reports to situation. The Emergency Plant and advises the Emergency Director Manager reports to and advises the on plant status and provides Emergency Director on facility status recommendations for emergency and provides recommendations for reclassification based upon technical emergency reclassifi cation based information and indications recorded upon technical information and in the TSC. indications recorded in the TSC. 5.2.5, Emergency The Emergency Director Advisor is Deleted. The Emergency Director Advisor is not a position in the Post-Director Advisor responsible for accompanying the Shutdown ERO. 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. 5.3.2, Unit Supervisor During power operations, the Unit Deleted. The title "Unit Supervisol will not exist in the post shutdown on-Supervisor is responsible for shift staff. 22

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section 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 Director duties, if the Shift Manager becomes incapacitated. 5.3.3, Shit Engineer During an emergency, the Shift Deleted. The Shifi Engineer (Shift Technical Advisor) is not part of the on-(Shift Technical Engineer (Shift Technical Advisor), if shift staff post shutdown. Advisor) 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. The Shift Engineer (Shift Technical Advisor) will assume the role of Emergency Direclor 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 23

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section circumstances, this position may be filled by an onshift SRO assigned another function. 5.3.5, Onshift During normal power operations, the Deleted Dedicated Maintenance personnel will not be part of the on-shift Maintenance Support Onshift Maintenance personnel staff post shutdown. Maintenance activities will be performed by report to the Shift Engineer. Upon on-shifi personnel assigned other functions. 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 lnstrument and Controls Maintenance support functions. 5.4.1, Overview The assignment of responsibilities in The assignment of responsibilities in Editorial changes - title, grammar the Onsite Emergency Response the Onsite Emergency Response Organization is ultimately the Organization is ultimately the responsibility of the Vice President, responsibility of the General Plant Nuclear. However, the Emergency Manager. However, the Emergency Response Manager is responsible Response Manager is responsible for establishing and maintaining a for establishing and maintaining a predefined Onsite Emergency predefi ned Onsite Emergency Resoonse Oroanization. Altemate Response Orqanization. Altemate 24

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section assignments to various positions are assignments to various positions are specified to provide for timely, specified to provide for timely, automatic, and unambiguous automatic, and unambiguous staffing manning to satisfy emergency to satisfy emergency response response requirements. requirements. 5.4.1 .a, Control Room Control Room staff will control the Control Room staff will control the The plant will no longer be operating. SFP activities replace operation of the power plant during operation of the SFP during both reactor operation. both normal and emergency normal and emergency conditions. operations. 5.4.2, Direction and The primary function of the Onsite The primary funclion of the Onsite The plant will no longer be operating. SFP activities replace Coordination and Near Site Emergency Response and Near Site Emergency Response reactor operation. Organization is to relieve the Control Organization is to relieve the Control Room staff of those duties and Room staff of those duties and responsibilities not directly related to responsibilities not directly related to the operation of the primary and the safe storage of spent fuel in the secondary plant systems. SFP. 5.4.3, Control Room At the ALERT level or greater, Deleted. Reflect the permanently shutdown and defueled condition additional operators will be assigned to assist in the OSC, under the direction of the OSC Manager. 5.4.4.a, Emergency The Emergency Assistant Plant The Emergency Assistant Plant The Emergency Assistant Plant Manager may respond to the Assistant Plant Manager is the senior Company Manager is responsible for TSC. Manager, 1st representative within the Control coordination and interface between paragraph Room. The Emergency Assistant the TSC emergency organization Plant Manager is responsible for and the facility. The Emergency coordination and interface between Assistant Plant Manager advises the the TSC emergency organization Emergency Plant Manager on facility and the plant. The Emergency status and trends, and their potential Assistant Plant Manaoer advises the imoact on orotec{ive action 25

Emergency PIan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Emergency Plant Manager on plant recommendations and emergency status and trends, and their potential classification. impact on protective action recommendations and emergency classification. 5.4.4.c, Technical The TSC Engineering Manager is The TSC Engineering Manager is The TSC Engineering Manager will perform Engineering Support Center (ISC) responsible for the coordination and responsible for performing an functions in the TSC. The spectrum of credible and operational Engineering Manager, supervision of TSC engineering engineering assessment of facility events, and the quantity and complexity of activities required for 1st paragraph activities associated with conditions and/or actions needed to the safe storage of spent nuclear fuel is reduced as compared to development of emergency mitigate damage to the facility, an operating plant. The set of plant equipment required in the procedures to terminate or mitigate continuously evaluate the need for permanently defueled condition is also greatly reduced, which the emergency situation. engineering resources, and the reduces the assessment and mitigation activities the TSC must coordination and supervision of TSC perform. engineering activities associated with development of emergency procedures to terminate or mitigate the emergency situation. 5.4.4.c, Technical Reporting to the TSC Engineering Other augmented, qualified TSC Engineers will be called in as needed. Support Center (ISC) Manager are the TSC Engineering engineering resources that may be Engineering Manager, Lead, and the TSC Operations Lead requested report to the TSC last paragraph Engineering Manager. 5.4.4.d, TSC The TSC Engineering Lead is Deleted. After docketing of the certification of permanent cessation of Engineering Lead staffed as appropriate, and is power operations and permanent removal of fuel from the reactor responsible for coordinating the TSC vessel, the 10 CFR 50 license will no longer authorize reactor Engineers. operation or emplacement or retention of fuel in the reactor vessel. As a result the TSC Engineering Lead and engineers are The TSC Engineering Lead reports no longer needed. to the TSC Engineering Manager and interfaces with the TSC 26

Emergency Plan After (Pending Revision Number) Reason for Change Before (Rev. 33) Section Operations Lead, and the The Engineering Manager will perform Engineering functions in Emergency Radiation Protection the TSC. The speclrum of credible and operational events, and Manager. the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an Reporting to the TSC operating plant. The set of plant equipment required in the Engineering Lead are permanently defueled condition is also greatly reduced, which engineers with expertise in reduces the assessment and mitigation activities the TSC must the following disciplines: perform.

1. Core/Thermal Hydraulics

2. Electrical

3. Mechanical

4. lnstrument and Control 5.4.4.e, TSC The TSC Operations Lead is staffed Deleted. The Engineering Manager will perform Engineering functions in Operations Lead as appropriate, and is responsible the TSC. The speclrum of credible and operational events, and for coordinating and supervising the the quantity and complexity of activities required for the safe TSC Operations Engineering group. storage of spent nuclear fuel is reduced as compared to an The TSC Operations Lead operating plant. The set of plant equipment required in the coordinates engineering tasks permanently defueled condition is also greatly reduced, which assigned to the TSC and Operations reduces the assessment and mitigation activities the TSC must Engineering staff. perform.

The TSC Operations Lead reports to the TSC Engineering Manager, and interfaces with the TSC Engineering Lead and the Emergency Radiation Protection Manager. 27

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Reporting to the TSC Operations Lead are personnel with expertise in various aspects of plant operations and computer technology. 5.4.4.9, Emergency 1. The Emergency Facilities Deleted. The Emergency Facilities Services Manager position will not exist Facilities Services Services Manager reports to the in the post-shutdown ERO and tasks have been reassigned to Manager Emergency Offsite Manager in the remaining ERO personnel. Emergency Operations Facility and is responsible for coordinating with emergency response facility management to ensure the sufflcient 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 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:

28

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section a) Food and sleeping supplies. b) Road maintenance, (e.9., 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.

5.4.5.a, OSC Reporting to the OSC Manager are The OSC Radiation Protection The Assistant OSC Manager position is eliminated from the Post-Manager,2nd the Assistant OSC Manager, and the Coordinator reports to the OSC Shutdown ERO. Tasks transferred to remaining ERO personnel. paragraph OSC Radiation Protection Manager. Coordinator. 5.4.5.b, Assistant The Assistant OSC Manager reports Deleted. The Assistant OSC Manager position is eliminated from the Post-OSC Manager to and assists the OSC Manager as Shutdown ERO. Tasks transferred to remaining ERO personnel directed. He is responsible for the OSC personnel pool, and assumes the duties and responsibilities of the OSC Manager in his absence. 29

Emergency Plan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section 5.4.5.c, The OSC The OSC Radiation Protection The OSC Radiation Protection Augmenting Chemistry Technician positions will not exist in the Radiation Protection Coordinator dispatches RP and Coordinator dispatches technicians Post-Shutdown ERO. Coordinator, 1"t Chemistry technicians within the within the protected area to survey, paragraph protecled area to survey, sample, sample, and analyze various and analyze various systems and/or systems and/or areas to determine areas to determine the emergency the emergency radiological radiological conditions. conditions. 5.4.5.c, The OSC Reporting to the OSC Radiation Reporting to the OSC Radiation On-shift Chemistry Technician positions will not exist in the post Radiation Protection Protection Coordinator are all RP Protection Coordinator are all RP shutdown condition. Coordinator, last and Chemistry testers not testers not specifically assigned paragraph specifically assigned other other responsibilities within the responsibilities within the emergency emergency organization. organization. 5.4.5.f, OSC Pool Members of the OSC Personnel Members of the OSC Personnel The Assistant OSC Manager position will not exist in the Post-Personnel Pool report to the Assistant OSC Pool report to the OSC Manager Shutdown ERO. Manager. 5.4.5.9, OSC System A minimum of three OSC Systems Deleted. The Engineering Manager will perform Engineering functions in Engineers Engineers will be called out to the TSC/OSC. The spectrum of credible and operational events, support OSC activities. The and the quantity and complexity of activities required for the safe disciplines represented will include storage of spent nuclear fuel is reduced as compared to an primary systems, secondary operating plant. The set of plant equipment required in the systems, and electrical and controls. permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC/OSC The OSC Systems Engineers will must perform. report to the OSC Manager, and interface with the various emergency repair teams, and the TSC engineers. 30

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 5.5.1, Overview The assignment of responsibilities in The assignment of responsibilities in Editorial changes - title, grammar the Near Site Emergency Response the Near Site Emergency Response Organization is ultimately the Organization is ultimately the responsibility of the Vice President, responsibility of the General Plant Nuclear. Manager. 5.5.2.a, NRC Liaison The NRC Liaison is responsible for Deleted The NRC Liaison position will not exist in the Post-Shutdown establishing and maintaining ERO. communications with the Nuclear Regulatory Commission (NRC): The NRC Liaison will be present at meetings between the Emergency Response Organization and the NRC. 5.5.2.b, EOF The EOF Operations Advisor is Deleted The EOF Operations Advisor position will not exist in the Post-Operations Advisor responsible for gathering, Shutdown ERO. 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. 5.5.2.c, Dose The Dose assessment Coordinator The Dose assessment Coordinator The EOF Operations Advisor position will not exist in the Post-Assessment interfaces with the EOF Operations interfaces with the Emergency RP Shutdown ERO. Coordinator, 2nd Advisor and the Emergency RP Manager. paragraph Manager. 31

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 5.5.2.d, Emergency The Emergency Planning Advisor The Emergency Planning Advisor is The Emergency Facilities Services Manager position will not exist Planning Advisor, 2nd interfaces with the Emergency responsible for the procurement of in the Post-Shutdown ERO. paragraph Facilities Services Manager for the personnel and equipment. procurement of personnel and equipment. 5.5.2.d, Emergency Reporting to the Emergency The EOF Communications Staff The Log and Status Board Keepers positions will not exist in the Planning Advisor, 3rd Planning Advisor are the EOF report to the Emergency Planning Post-Shutdown ERO. paragraph Communications Staff, and the Log Advisor. and Status Board Keepers (EOF). 5.5.2.d, Emergency The EOF communications staff is The EOF communications staff is Reflect reassignment of the NRC Liaison//Communicator tasks. Planning Advisor, last comprised, at a minimum, of two comprised, at a minimum, of two paragraph communicators who are responsible communicators who are responsible for communications with the Ottawa for communications with the Ottawa County Emergency Operations County Emergency Operations Center, the Lucas County Center, the Lucas County Emergency Operations Center, the Emergenry Operations Center, the State of Ohio, and the Corporate State of Ohio, and the Corporate Assistance Center (CAC). Assistance Center (CAC), and the Nuclear Regulatory commission (NRC). A member of the EOF communications staff will be present at meetings between the ERO and the NRC. 5.8.3.a.2 The Emergency Plans for DBNPS, The Post-Shutdown Emergency Editorial - grammar State of Ohio, Ottawa County and Plan for DBNPS, and the emergency Lucas County, have been formulated plans for the State of Ohio, Ottawa to provide timely notification and County and Lucas County, have close coordination with these been formulated to provide timely agencies. 32

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section notification and close coordination with these agencies. 5.8.4.a, lnstitute of 1. One of the roles of INPO is to Deleted DBNPS will no longer be an operating plant. Support from INPO Nuclear Power assist the affected utility in quickly is no longer expected. Operations (INPO) 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 conceming the incident, that is applicable to their operations. 33

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 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. lf 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. u

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 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. 5.8.4.b Nuclear Steam Supply System ArchitecUEngineer Support DBNPS will no longer be an operating nuclear power plant. (NSSS) Vendor and NSSS support is no longer required. ArchitecUEnoineer Suoport 5.8.4.b, 1"t paragraph The NSSS vendor for the Davis- Deleted DBNPS will no longer be an operating nuclear power plant. Besse plant was the Babcock and NSSS support is no longer required. Wilcox (B&W) Company. Babcock & Wilcox later became B&W Nuclear Technology (BWNT) and is currently known as Areva NP. 5.8.4.b, 2nd paragraph These two firms can be called on This firm can be called on during DBNPS will no longer be an operating nuclear power plant during emergency situations to emergency situations to provide the NSSS support is no longer required. provide the technical analysis and technical analysis and engineering engineering support necessary to support necessary to mitigate mitiqate abnormal plant conditions abnormal facilitv conditions 35

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Table 5-1A, ONSHIFT Shift Manager (SRO) - 1 Shift Manager (SM) / Certified Fuel DBNPS will no longer be an operating nuclear power plant. The MINIMUM STAFFING Handler (CFH) - 1 following on-shift positions will be eliminated: Unit Supervisor (SRO) - o 1 REQUIREMENTS, Non-Certified Operator (NCO) - 2 Shift Engineer/Shift Technical Advisor Functional Area Plant Operations and Shift Engineer 1 o Two (2) Reactor Operators Assessment of Reactor Operator - 2 Following permanent cessation of operations and removal of fuel Operational Aspects Non-Licensed Operator (EO3) - 1 from the reactor vessel, Operations on-shift personnel will consist of one (1) Shift Manager (SM) / Certified Fuel Handler (CFH) and two (2) Non-Certified Operators (NCOs). Title changes to CFH and NCO are dependent upon NRC approval of proposed changes to the DBNPS Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs. These staffing levels have been evaluated in the DBNPS analysis of proposed post shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition. Table 5-1A, ONSHIFT Local/State - NLO or above Local/State - NCO or above Title changes for the NLO to NCO are dependent upon NRC MINIMUM STAFFING approval of proposed changes to the DBNPS Technical REQUIREMENTS, Federal - NLO or above Federal - NCO or above Specifications that replace references for reactor operators and Functional Area non-licensed operators with references to NCOs. Notifications & Communication Table 5-1A, ONSHIFT Dose Assessment - Shift Engineer Dose Assessment - NCO or above NCO or above replaces Shift Engineer (STA) MINIMUM STAFFING (sTA) - 1(a) - 1(a) REQUIREMENTS, (a) May be filled by someone filling ta) May be filled by someone filling Functional Area another position having functional another position having funclional qualifications qualifications 36

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Radiological Assessment Table 5-1A, ONSHIFT Chemistry - Chemistry Technician - RP Technician - 1(a) DBNPS will no longer be an operating nuclear power plant. The MINIMUM STAFFING 1 on-shift Chemistry Technician position will be eliminated. ra) May be filled by someone filling REQUIREMENTS, another position having functional Functional Area qualifications Removal of the on-shift Chemistry Technician has been Radiological evaluated in the DBNPS analysis of proposed post-shutdown on-Assessment shift staffing in conjunciion with the postulated accidents that will be applicable in the permanently defueled condition. Table 5-1A, ONSHIFT Technical Support - Ops - Shifi Technical Support - Ops - NCO or NCO or above replaces Shift Engineer (STA) MINIMUM STAFFING Engineer (STA) - 1(") above - 1(") REQUIREMENTS, (a) (a) May be filled by someone filling May be filled by someone filling Functional Area Plant another position having functional another position having functional System Engineering, qualifications qualifications Repair and Mitigative Actions Table 5-'1A, ONSHIFT Core Damage - Shift Engineer Deleted DBNPS will no longer be an operating nuclear power plant. MINIMUM STAFFING (sTA) - 1c) REQUIREMENTS, ra) May be filled by someone filling After docketing of certifications of permanent cessation of power Functional Area Plant operations and permanent removal of fuel from the reactor another position having functional System Engineering, qualifications vessel, the 10 CFR 50 license will no longer authorize reactor Repair and Mitigative operation or emplacement or retention of fuel in the reactor Actions vessel. As a result, Core Damage assessment is no longer needed. Table 5-1A, ONSHIFT Radiation Proteclion - RP Radiation Protection - RP Removal of one on-shifl RP Technician has been evaluated in MINIMUM STAFFING Technician - 2(") Technician - 1(a) the DBNPS analysis of proposed post-shutdown on-shifi stafflng REQUIREMENTS, in conjunction with the postulated accidents that will be applicable Functional Area ln- in the permanently defueled condition. 37

Emergency Plan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section Plant Proteclive (a) May be filled by someone filling Actions another position having functional qualifications Table 5-1A, ONSHIFT Fire Brigade Captain (RO/EO3) - 1 Fire Brigade Captain (NCO) - 1(a) Fire Brigade will be composed of the Fire Brigade Captain (NCO) MINIMUM STAFFING and four other trained and qualified individuals. REQUIREMENTS, Fire Brigade Member - 4 Fire Brigade Member - 4 Functional Area Fire Fighting Table 5-1A, ONSHIFT NLO NCO Title change MINIMUM STAFFING REQUIREMENTS, Functional Area 1st Aid and Rescue Table 5-1A, ONSHIFT 15 10 Reduction in the number of on-shifi staff has been evaluated in MINIMUM STAFFING the DBNPS analysis of proposed post-shutdown on-shifi staffing REQUIREMENTS in conjunction with the postulated accidents that will be applicable in the permanently defueled condition. TOTAL Table 5-1A. ONSHIFT Personnel assigned to the shift in Personnel assigned to the shift in DBNPS will no longer be an operating nuclear power plant. MINIMUM STAFFING excess of the minimum staffing listed excess of the minimum stafiing listed REQUIREMENTS above may be assigned to any of the above may be assigned to any ofthe Removal of the on-shift Chemistry Technician has been emergency positions in functions 2 emergency positions in functions 2 evaluated in the DBNPS analysis of proposed post-shutdown on-Notes through 9 for which they are through 9 for which they are shift staffing in conjunciion with the postulated accidents that will qualified. Appendix F, Davis-Besse qualified. Appendix F, Davis-Besse be applicable in the permanently defueled condition. Nuclear Power Station (DBNPS) Nuclear Power Station (DBNPS) ERO On-Shift Staffing Analysis ERO PostShutdown On-Shift Report, documents the minimum Staffing Analysis Report, documents shift's ability to implement the the minimum shift's ability to emerqencv olan. implement the emerqency olan. 38

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section Operations personnel and Chemistry Operations personnel are qualified Technicians are qualified on survey on survey instruments instruments Table 5-1B, Emergency Assistant Plant Manager Emergency Assistant Plant Manager Note 3 added to Unusual Event column and Alert, Site Area, and AUGMENTED (1) (1 )3 General Emergency column to indicate the Emergency Assistant EMERGENCY Plant Manager can also respond to the TSC. RESPONSE Note 3: The Emergency Assistant STAFFING Plant Manager may respond to the REQUIREMENTS TSC. CONTROL ROOM Table 5-1B, Mechanical Maintenance (2) Mechanical Maintenance (1 ) ln the permanently shutdown and defueled condition there is no AUGMENTED longer any complex automatic control systems in service. The lnstrument & Controls (2) Electrical Maintenance (1) EMERGENCY augmenting technician positions can be reduced and the need for RESPONSE Electrical Maintenance (2) dedicated l&C maintenance technicians are not required. lf STAFFING conditions warrant, the OSC Manager can call out support as REQUIREMENTS necessary. OPERATIONS SUPPORT CENTER Table 5-18 Chemistry Technician (0) at 30 - 60 RP Technician (1) at 30 - 60 There is a significant decrease in the areas potentially requiring AUGMENTED minutes minutes Radiation Protection coverage in a permanently shutdown and EMERGENCY defueled condition.

RESPONSE

RP Technician (1) at 30 - 60 RP Technician (1) at 1 - 2 hours minutes STAFFING Removal of the on-shifi Chemistry Technician has been REQUIREMENTS RP Technician (3) at 1 - 2 hours evaluated in the DBNPS analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will OPERATIONS Chemistry Technician (1\ at 1 -2 be applicable in the permanently defueled condition. SUPPORT CENTER hours 39

Emergency Plan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section Table 5-1B, Core/Thermal Hydraulic Engineer (1 ) Deleted After docketing of the certifications of permanent cessation of AUGMENTED at 30 - 60 minutes power operations and permanent removal of fuel from the reactor EMERGENCY vessel, the 10 CFR 50 license will no longer authorize reactor RESPONSE operation or emplacement or retention of fuel in the reactor STAFFING vessel. As a result, core damage assessment is no longer REQUIREMENTS needed. TECHNICAL SUPPORT CENTER Table 5-18, TSC l&C Engineer (1) at 1 - 2 hours TSC l&C Engineer - Call in as The need for augmenting engineers is reduced. The TSC AUGMENTED necessary Engineering Manager, tasked with performing engineering EMERGENCY TSC Electrical Engineer ('l) al 1 - 2 assessments of plant conditions and actions needed to mitigate

RESPONSE

hours TSC Electrtcal Engineer - Call in as damage to the plant, will provide technical support in the Major necessary STAFFING TSC Mechanical Engineer (1) at 1 - Funclional Area of Plant System Engineering, Repair, and REQUIREMENTS 2 hours TSC Mechanical Engineer - Call in Conective Action. as necessary TECHNICAL SUPPORT CENTER Table 5-18, NRC Liaison (1) Deleted. The NRC Liaison position will not exist in the Post-Shutdown AUGMENTED ERO. EMERGENCY

RESPONSE

STAFFING REQUIREMENTS EMERGENCY OPERATIONS FACILITY 40

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section Figure 5-1, ONSHIFT Removed Chemistry, Shift Engineer Modified to reflect on-shifi organizational changes. EMERGENCY (STA), Onshift Maintenance and Unit ORGANIZATION Supervisor Figure 5-2, Removed Emergency Director Modified to reflect ERO changes. Emergency Response Advisor Organization (Page 1 of 10) Figure 5-2, Removed Recovery Advisor. Modified to reflec{ ERO changes. Emergency Response Eliminated Core Damage After docketing of the certifications of permanent cessation of Organization (Page 2 power operations and permanent removal of fuel from the reactor Assessment function from the TSC of 10) Engineering Manager. vessel, the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reaclor vessel. As a result, core damage assessment is no longer needed. Figure 5-2, Removed Shift Engineer (STA) Modified to reflect ERO changes. Emergency Response Organization (Page 3 of 10) Figure 5-2, Removed TSC Engineering Lead, Modified to reflect ERO changes. Emergency Response TSC Operations Lead, Core/Thermal Organization (Page 4 Hydraulic Engineer, TSC Mechanical of 10) Engineer, TSC Elecirical Engineer, TSC l&C Engineer, TSC Operations Engineers, TSC Computer Technician, SAM Engineer Figure 5-2, Removed OSC System Engineers, Modified to reflect ERO changes. Emergency Response RP Briefer/Debriefer, Assistant OSC Manaoer. OSC Team 41

Emergency Plan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section Organization (Page 6 Briefer/Debriefer, Operations of 10) Personnel Figure 5-2, Removed EOF Operations Advisor, Modified to reflecl ERO changes. Emergency Response Emergency Facilities Services Organization (Page 8 Manager, Assembly Area of 10) Coordinator, Maintenance Services personnel, Log and Status Board Keepers, Resource Coordinator, NRC Liaison, Warehouse pool personnel Figure 5-2, Reduced Dose Assessors from 2 to Modified to reflect ERO changes. Emergency Response 1 Organization (Page 9 of 10) Figure 5-2, Removed Public Affairs Duty Officer, Modified to reflect ERO changes. Emergency Response JIC Writer, News Statement Organization (Page Coordinator, JIC Communicator, PR 10 of 10) Communicator, AudioA/isual Coordinator 6.1, Activation of the The lnstitute of Nuclear Power Deleted DBNPS will no longer be an operating nuclear power plant. Emeroency Resoonse Operations (INPO) is notified at an Assistance from INPO is not expected. Oroanizations, 3d Alert or higher classification with bullet requests for assistance as necessary. 6.1.1.a Should emergency conditions arise, Should emergency conditions arise, Reflect the post shutdown on-shift staffing. it is expected that the Control Room it is expected that the Non-Certified Operator(s) and/or the Shift Operator(s) and/or the Shift Manager will be made aware of the Manager will be made aware of the situation bv alarms. instrument situation bv alarms. instrument 42

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section readings, reports, etc. The Control readings, reports, etc. The Non-Room Operator(s) will ensure that Certified Operator(s) will ensure that the Shift Manager is immediately the Shift Manager is immediately informed of the situation. informed of the situation. 6.1.1.b The Shift Manager, when informed The Shift Manager, when informed After docketing of the certifications of permanent cessation of of an emergency situation, is of an emergenry situation, is power operations and permanent removal of fuel from the reactor responsible for assessing the responsible for assessing the vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and emergency (e.9., plant systems and emergency (e.9., systems and SFP pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no reactor core status, radiological status, radiological conditions, etc.) longer authorize reactor operation or emplacement or retention of conditions, etc.) in the following in the following manner: fuel in the reactor vessel. As a result, reactor status is no longer manner: applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of the assessment. 6.1.1.b.1 Determine the immediate actions to Determine the immediate actions to After docketing of the certifications of permanent cessation of be taken (e.9., use of Abnormal be taken to ensure the safe and power operations and permanent removal of fuel from the reactor Procedures and the Emergency proper operation of the SFP. vessel, in accordance with 10 CFR 50.82(aX1Xi) and (ii), and Operating Procedure) to ensure the pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no safe and proper operation of the longer authorize reactor operation or emplacement or retention of plant. The Shift Engineer, acting as fuel in the reactor vessel. As a result, reactor status is no longer Shift Technical Advisor (STA), will applicable. With irradiated fuel being stored in the Spent Fuel advise and assist the Shift Manager Pool, it becomes the focus of the assessment. on matters pertaining to the safety and proper operation of the plant The Shift Engineer (STA) position will not exist in the post-with regards to nuclear safety. shutdown on-shift staff. 6.1.1.b.3.a) Ensure the safe operation of the Ensure the safe operation of the After docketing of the certifications of permanent cessation of plant. SFP. power operations and permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result. reactor status is no lonoer 43

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of operations. 6.2.3.a An increased amount of plant An increased amount of facility After docketing of the certifications of permanent cessation of instrumentation will be monitored. instrumentation will be monitored. power operations and permanent removal of fuel from the reactor (ln particular, indications of core (ln particular, indications of SFP vessel, in accordance with 10 CFR 10 CFR 50.82(a)(1)(i) and (ii), status, e.9., incore thermocouple status) and pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will readings, etc.) no longer authorize reactor operation or emplacement or retention of fuel in the reaclor vessel. As a result, reactor status is no longer applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of operations. 6.3, Mitioative Detailed operating procedures are Detailed operating procedures are After docketing of the certifications of permanent cessation of Actions, l"tparagraph available for use during avaihbb for use during power operations and permanent removal of fuel from the reactor emergencies, as well as during emergencies, as well as during vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and normal operations. Specific normal operations. Specific pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no Emergency Operating Procedures procedures are provided to assist longer authorize reactor operation or emplacement or retention of and Abnormal Procedures are the operators in placing the facility in fuel in the reactor vessel. As a result, reactor status is no longer provided to assist the operators in a safe condition, and taking applicable. With irradiated fuel being stored in the Spent Fuel placing the plant in a safe condition, necessary supplemental miti gative Pool, it becomes the focus of operations. Operations staff will no and taking necessary supplemental actions. ln addition, personnel are longer be required to implement emergency operating mitigative actions. ln addition, trained in the operation of the SFP procedures and the scope of the applicable abnormal response operations personnel are trained in systems and their associated procedures that remain will be significantly reduced. On-shifi the operation of the plant systems procedures, and are therefore staffing is trained in the operation of the SFP systems and their and their associated procedures, capable of taking appropriate associated procedures, and are therefore capable of taking and are therefore capable of taking mitigative actions based on their appropriate mitigative actions. appropriate mitigative actions based training, knowledge, and experience on their training, knowledge, and experience. 6.4.1.c,3'd bullet Dispersal of plant operators and Dispersal of Operations personnel, Reflect the change to post shutdown conditions. essential ERO members and essential ERO members 44

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 6.4.2, Offsite Responsibilig for implementing Responsibility for implementing Editorial change - grammar Protective Actions, 1st actions to protect personnel in offsite actions to protect personnel in offsite paragraph areas rests with State and local areas rests with State and local officials, and is described in detail in officials, and is described in detail the The Ohio Radioloqical The Ohio Radioloqical Emeroencv Emerqencv Preparedness Plan and Preparedness Plan and the Ohio the Ohio Emerqencv Ooerations Emerqencv Operations Plan (under Plan (under a separate cover), and a separate cover), and is is implemented in conjunction with implemented in conjunction with The The Ottawa Countv Radiolooical Ottawa County Radiolooical Emerqencv Resoonse Plan, and The Emerqencv Resoonse Plan, and The Lucas Countv Radioloqical Lucas Countv Radioloqical Emeroencv Resoonse Plan (under Emeroencv Resoonse Plan (under separate covers) separate covers) Table 6-6, ... such levels in milk should cause .. . such levels in milk should cause Editorial change - spelling GUIDELINES FOR surveilance and protective actions surveillance and protective actions PROTECTION for meat as appropriate. for meat as appropriate. AGAINST INGESTION OF CONTAMINATION, Note 2 7.0, EMERGENCY Many of the DBNPS facilities and Many of the DBNPS facilities and Reflect the change to post shutdown conditions. FACILITIES AND much of the equipment is normally much of the equipment is normally EQUIPMENT,last used for routine plant operations. used for routine activities. paragraph 7.1.1.a The Control Room is the location The Control Room is the location After docketing of the certifications of permanent cessation of from which the plant is operated. lt from which the SFP systems are power operations and permanent removal of fuel from the reactor contains the instrumentation, monitored. lt contains the vessel, in accordance with 10 CFR 50.82(a)(1Xi) and (ii), and controls. and disolavs for: pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no 45

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section instrumentation, controls, and longer authorize reactor operation or emplacement or retention of

1. Nuclear systems displays for: fuel in the reactor vessel. As a result, reactor status is no longer applicable. With irradiated fuel being stored in the Spent Fuel

2. Reactor coolant systems

1. Eleclrical systems Pool, it becomes the focus of operations.

3. Steam systems

4. Electricalsystems

2. Systems associated with the SFP Editorial change - title.

5. Safety systems (including

3. Accident monitoring systems.

engineered safety features) The on-shifi staff is in accordance

6. Accident monitoring systems. with TS 5.2.2. Control manipulations and the safe operation of the SFP The operating shift is staffed in are direcled by the Shift Manager accordance with TS 5.2.2 and TRM (qualified as a Certified Fuel Handler 1 0.2.1 requirements. Control (CFH) and are performed by Non-manipulations and the safe Certified Operators.

operation of the plant are directed by the Senior Reaclor Operator Licensed Shift Manager and Unit Supervisor, and are performed by Licensed Reac{or Operators. 7.1.1.b During abnormal operating During abnormal conditions, the Reflect the permanently shutdown and defueled condition conditions, the complexity of Station complexity of Station responsibilities responsibilities increases increases and the Control Room significantly and the Control Room transforms into an emergency transforms into an emergency response center. response center. 7 .1.1.b.4 Management of plant operations. Management of SFP operations. After docketing of the certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(aX1Xi) and (ii), and pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no lonoer authorize reactor ooeration or emolacement or retention of 46

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section fuel in the reactor vessel. As a result, reactor status is no longer applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of operations. 7.1.1.b.8 Restoring the plant to a safe Restoring the SFP to a safe After docketing of the certifications of permanent cessation of condition. condition. power operations and permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, reactor status is no longer applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of operations. 7.1.1.b, last During emergencies, the Emergency During emergencies, the Emergency Emergenry Assistant Plant Manager location is flexible paragraph Assistant Plant Manager uses the Assistant Plant Manager may use Shift Manager's Offlce, which is the Shift Manager's Office, which is within the Control Room envelope, within the Control Room envelope, to observe and provide guidance to to observe and provide guidance to the Shift Manager for direction and the Shift Manager for direction and control of in-plant aclivities. control of facility activities. 7.2, Davis-Besse The DBAB contains the Emergency The DBAB contains the Emergency Reflect the permanently shutdown and defueled condition. Administration Response Facilities (ERFs) Response Facilities (ERFs) Buildinq (DBAB) necessary to assist Control Room necessary to assist Control Room Facilities personnel in accident assessment personnel in accident assessment and abnormal operating conditions and abnormal conditions 7.2,2d bullel Relieve the Control Room staff of Relieve the Control Room staff of After docketing of the certifications of permanent cessation of peripheral duties and peripheral duties and power operations and permanent removal of fuel from the reactor communications not directly related communications not directly related vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and to reactor system manipulations. to SFP system manipulations. pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no lonoer authorize reactor ooeration or emolacement or retention of 47

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section fuel in the reactor vessel. As a result, reactor status is no longer applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of operations. 7.2, 4th bullet Provide assistance to the operators Provide assistance from technical Reflect the permanently shutdown and defueled condition from technical personnel who have personnel who have comprehensive comprehensive plant data at their facility data at their disposal disoosal 7.2, 7th bullet Provide relevant plant data to the Provide relevant facility data to the Reflect the permanently shutdown and defueled condition NRC for its analysis of abnormal NRC for its analysis of conditions olant ooeratino conditions 7.3, Near Site The facility has access to station The facility has access to station Editorial changes - capitalization. Emergency Response radio and public Address systems. radio and public address systems. Facility The facility is equipped with an The facility is equipped with an uninterruptable power system and uninterruptable power system and an emergency diesel generator. The an emergency diesel generator. The Near Site Emergency response Near Site Emergency Response Facilities include the following: Facilities include the following: 7.6.2.a.2.c Emergency Response Data System Deleted ERDS is no longer required following permanent shutdown. (ERDS) data lines. 7.9.1.c The safety-related radiation monitors Radiation monitors are powered Reflect the permanently shutdown and defueled condition are powered from the essential from the essential instrument instrument distribution panels. The distribution panels. The non-non-essential radiation monitors are essential radiation monitors are powered from the uninterruptible powered from the uninterruptible instrument distribution panels. instrument distribution panels. 7.9.1.d \A/ith the exception of the Kaman Each radiation monitor is capable of Editorial - Kaman monitors no longer used. monitors, each radiation monitor is being checked periodically with capable of being checked solenoid actuated check sources. 48

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section periodically with solenoid actuated check sources. 7.9.2, Area Radiation There are a total of 40 area monitors Area monitors consist of two types, Reflect the permanently shutdown and defueled condition. Monitoring, 1"t consisting of two types, Geiger- Geiger-M ueller detectors and The number of area radiation monitors will change. paragraph Mueller detectors and lonization lonization Chamber detectors. Chamber detectors. 7.9.2, Area Radiation These detectors cern also monitor Deleted Reflect the permanently shutdown and defueled condition Monitoring,2nd the high level of radiation that would paragraph be characteristic of the post-accident atmosphere in containment. The detectors are desensitized by a lead shield. 7.9.7, Seismic A video display will provide quick, A video display will provide quick, Reflect the permanently shutdown and defueled condition Monitoring System, accurate determinations to be made accurate determinations to be made 3rd paragraph, last based on the seismic event, and to based on the seismic event. sentence determine if a plant shutdown is required. 7.9.7, Seismic ln keeping with the purposes of the ln keeping with the purposes of the Reflect the permanently shutdown and defueled condition. Monitoring System,4th system, loss of site power will not system, loss of site power will not paragraph prevent system operation. Backup prevent system operation. Backup power is supplied from the Station power is supplied from an intemal Battery, and also an internal battery battery in the network control center in the network control center and and each recorder. each recorder. 7.9.9, Control Room Control Room lnstrumentation Control Room lnstrumentation After docketing of the certifications of permanent cessation of lnstrumentation, 1"t measures appropriate parameters measures appropriate parameters power operations and permanent removal of fuel from the reactor paragraph that are indicative of the status of that are indicative of the status of vessel, in accordance with 10 CFR 50.82(a)(1Xi) and (ii), and various plant systems and the various SFP systems. pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no reactor itself. longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, reactor status is no lonoer 49

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of operations. 7.9.9, Control Room The Post Accident Monitoring Paragraph is deleted After docketing of the certifications of permanent cessation of lnstrumentation, 2nd System (PAMS) is also available to power operations and permanent removal of fuel from the reaclor and 3'd paragraphs follow the course of an accident with vessel, in accordance with 10 CFR 50.82(aX1Xi) and (ii), and wide range instrumentation. This pursuant to 10 CFR 50.82(aX2), the 10 CFR 50 license will no system will provide to the plant longer authorize reactor operation or emplacement or retention of operators, the essential safety status fuel in the reactor vessel. As a result, reactor status is no longer information necessary to allow them applicable. With irradiated fuel being stored in the Spent Fuel to return the plant to a maintained, Pool, it becomes the focus of operations. safe, shutdown condition. USAR Table 7.Sl provides a listing USAR Table 7.5-1 provides a listing and a description of Control Room and a description of Control Room instrumentation, including PAMS instrumentation that would be used that would be used in performing in performing continued assessment continued assessment of plant of facility conditions. conditions. 7.9.10, Laboratory The Davis-Besse laboratory facilities The Davis-Besse laboratory facilities After docketing the certifications of permanent cessation of power Facilities, 1st are equipped to provide the water are equipped to provide the water operations and permanent removal of fuel from the reactor paragraph chemistry and radiochemical chemistry and radiochemical vessel, in accordance with 10 CFR 50.82(a)(1Xi) and (ii), and analysis support required during analysis support required during pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no normal plant operations. This normal SFP operations. This longer authorize reactor operation or emplacement or retention of equipment can also be utilized in the equipment can also be utilized in the fuel in the reactor vessel. As a result, reactor status is no longer analysis of abnormal events to assist analysis of abnormal events when applicable. With irradiated fuel being stored in the Spent Fuel in the diagnosis of plant operations conditions permit. Pool, it becomes the focus of operations. when conditions permit. 7.9.10.b For reactor coolant system Deleted No longer required post shutdown. samolino. a shielded- hioh-oressure 50

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section sampler is available for pressurized samples. These samples are obtained using the Post Accident Sampling System (PASS) which was designed specifically for this purpose. 7.9.10.c For containment atmosphere Deleted. No longer required post shutdown. sampling, the nonnal sampling procedure is used. lf 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 Emergencv Grab Sample System. 7.12, Damaqe Control Each maintenance crew is qualified Each maintenance crew is qualified Reflect the permanently shutdown and defueled condition Eouipment,2nd and, when required, certified to and, when required, certified to paragraph perform the tasks associated with perform the tasks associated with their craft in the working their craft in the working environment of a nuclear plant. environment of a permanently shutdown and defueled nuclear plant. Figure 7-1, lnstitute of Nuclear Power Deleted. Davis-Besse will no longer be an operating plant and support EMERGENCY Operations Emergency Response from INPO is not expected. FACILITIES BY Center (ERC) Atlanta Georgia GENERAL LOCATION 51

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 8.0, MAINTENANCE Efforts will be made to assure Efforts will be made to assure Editorial change - title OF EMERGENCY continuous emergency continuous emergency PREPAREDNESS preparedness and operational preparedness and operational readiness among Company readiness among Company personnel and the offsite response personnel and the offsite response agencies and organizations. The agencies and organizations. The Vice President - Nuclear has been General Plant Manager has been assigned the overall responsibility assigned the overall responsibility for emergency preparedness as for emergency preparedness as related to the DBNPS. This related to the DBNPS. This responsibility includes not only responsibility includes not only maintenance of the DBNPS maintenance of the DBNPS Post Emergency Plan and Emergency Shutdown Emergency Plan and Plan Procedures, but also its Emergency Plan Procedures, but interrelationships with state, federal also its interrelationships with state, and county plans; agreement lefters; federal and county plans; agreement corporate policy and plans; and letters; corporate policy and plans; other related plans, programs, and and other related plans, programs, procedures. The Vice President - and procedures. The General Plant Nuclear is also responsible for Manager is also responsible for training of personnel who implement training of personnel who implement the Plan and Procedures. To assist the Plan and Procedures. To assist the Site Vice President - DB Nuclear the General Plant Manager in in meeting these assigned meeting these assigned responsibilities, an Emergency responsibilities, an Emergenry Response Manager, has been Response Manager, has been designated. The specific designated. The specific responsibilities of the Emergency responsibilities of the Emergency Resoonse Manaoer are described in Resoonse Manaoer are described in 52

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section the following subsections; and in the following subsections; and in particular, subsection 8. 1.3. particular, subsection 8. 1.3. 8.1.1, Training, 1"t All personnel permifted access to All personnel permitted access to Editorial change - title. paragraph the DBNPS protected area will take the DBNPS protected area willtake Reflect the change to post shutdown staff, which will include part in a formal training program part in a formal training program CFHs rather than licensed operators. under the direction of the Vice under the direction of the General President - Nuclear. This training Plant Manager. This training program provides for the program provides for the indoctrination of Company indoctrination of Company employees and contractors. ln employees and contractors. ln addition it provides specialized addition it provides specialized training for licensed operators, training for CFHs, chemistry chemistry personnel, radiation personnel, radiation protection protection personnel, and personnel personnel, and personnel assigned assigned specific responsibilities in specific responsibilities in the ERO. the ERO. 8.1.1, Training, 2nd The Vice President - Nuclear is The General Plant Manager is Editorial change - title. paragraph responsible for ensuring that responsible for ensuring that personnel in each department personnel in each department receive the appropriate training. The receive the appropriate training. The Nuclear Group Department Directors Nuclear Group Department Directors are responsible for identifying are responsible for identifying training required for each individual's training required for each individual's job specialty. Training in support of job specialty. Training in support of the Emergency Plan, includes the the Post-Shutdown Emergency Plan, following: includes the following: 8.1.1.a All DBNPS staff personnel requiring All DBNPS staff personnel requiring Reflect the permanently shutdown and defueled condition. unescorted access will receive unescorted access will receive Simplifies the Emergency Plan by replacing an explicit list with a training related to Emergency industry standard training for reference to industry standard training. 53

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Response. This training will be unescorted access to a nuclear completed initially, prior to being power plant and any specific training granted unescorted access, and determined by DBNPS post annually to maintain unescorted shutdown. access. With regard to Emergency Deleted. Response, the following objectives have been established:

1. State the purpose of the Post-Shutdown 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 Post-Shutdown Emergency Plan implementation.

5. State the purpose and importance of accountability.

6. ldentify the location of emergency facilities and assembly areas inside the Protected Area and Owner Controlled Area.

54

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section

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. ldentify the appropriate communication system to be used for reporting emergencies, locating an individual in the facility, and conducting lengthy discussions.

11. ldentify and discuss operation of the radiation exposure control criteria for personnel during an emergency for the persons who have access to Radiation Restricted Areas.

8.1 .2.a,3'o paragraph All drills and exercises are subject to All drills and exercises are subject to Site Vice President, DB Nuclearwill not exist in the post the approval of the General Plant the approval of the General Plant shutdown organization. Manager. In addition, the Site Vice Manager. President, DB Nuclear will approve the Biennial Exercise. 55

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 8.1.2.b.3 Obtain the approval of the General Obtain the approval of the General Site Vice President, DB Nuclearwill not exist in the post Plant Manager (DB), and the Site Plant Manager (DB). shutdown organization. Vice President-DB Nuclear (for the Biennial Exercise). 8.1.2.c.6.b An annual drill will be conducted Deleted No longer required post shutdown which includes an analysis of actual in-plant liquid samples (Reactor Coolant System) with simulated elevated radiation levels. 8.3, Review and This is more clearly defined in the This is more clearly defined in the Editorial - simplifi cation. Uodate of the Updated Safety Analysis Report Updated Safety Analysis Report Emerqencv Plan and (USAR), Section 13.3 (usAR). Emerqencv Plan Procedures. l"t paraoraph, last sentence 8.3.2, last paragraph Results of each annual and biennial Results of each annual and biennial Site Vice President, DB Nuclear will not exist in the post review and update (if needed) of the review and update (if needed) of the shutdown organization. Davis-Besse Nuclear Power Station Davis-Besse Nuclear Power Station Emergency Plan and Emergency Post-Shutdown Emergency Plan and Plan procedures will be repoiled to Emergenry Plan procedures will be the Site Vice President - DB reported to the General Plant Nuclear. Manager. Table 8-1, PERIODIC Emergency Assistant Plant Manager Deleted. This training is no longer applicable in the permanently shutdown TRAINING OF and defueled condition. Station personnel designated as EMERGENCY Emergency Assistant Plant Manager

RESPONSE

PERSONNEL Emergency Assistant Plant Manager shall oeriodicallv receive trainino on 56

Emergency Plan Reason for Change Before (Rev. 33) After (Pending Revision Number) Section DBNPS Emergency and Abnormal Operating Procedures and reactor thermal shock considerations equivalent to that received by SRO licensed individuals Table 8-1, PERIODIC Licensed Operators Certified Fuel Handlers Editorial change - title. TRAINING OF Shift Managers Shift Managers EMERGENCY RESPONSE Unit Supervisors Other Certified staff members PERSONNEL Other licensed staff members Certified Fuel Handlers receive extensive on-the-job and formal Reactor Operators and Senior training as scheduled and conducted Reactor Operators receive extensive by the CFH training program. This on-the-job and formal training as program includes a comprehensive scheduled and conducled by the review of the DBNPS Post operator requalifi cation training program. This program shall include Shutdown Emergency Plan and the Emergency Plan Procedures. a comprehensive review of the DBNPS Emergency Plan and the Emergency Plan Procedures. Table 8-1, PERIODIC Personnel responsible for Personnel responsible for Reflect changes for post shutdown staffing. TRAINING OF assessment of emergencies assessment of emergencies Reflect the change to post shutdown. EMERGENCY Emergency Director, Emergency Emergency Director, Emergency

RESPONSE

Plant Manager, Emergency Offsite Plant Manager, Emergency Offsite Site Vice President - DB Nuclear will not exist post shutdown. PERSONNEL Manager, Shift Managers, Key Manager, Shift Managers, Shift Technical Advisors (STAs), Key Emergency Response Personnel Emergency Response Personnel 57

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section Staff personnel designated by the Staff personnel designated by the General Plant Manager who may act General Plant Manager who may act as OSC and TSC Managers. as OSC and TSC Managers. Other members of the Nuclear Training will include the Post-Group staff as designated by the Shutdown Emergency Plan, Site Vice President - DB Nuclear Emergency Plan Procedures, Training will include the Emergency Technical Specifications (that are referenced in the Emergency Action Plan, Emergency Plan Procedures, Levels), and other station programs, Technical Specifications (that are plans, and procedures. The listed referenced in the Emergency Action individuals attend at least one Levels), and other station programs, plans, and procedures. The listed meeting per year to receive training on the Post-Shutdown Emergency individuals attend at least one Plan and Emergency Plan meeting per year to receive training Procedures. Detailed instructions on the Emergency Plan and with special attention given to the Procedures. Detailed instructions use of either dose assessment or with special aftention given to the en gineering assessment techniques use of either dose assessment or is provided based on the role they engineering assessment techniques is provided based on the role they are expected to play during an emergency. Personnel shall are expected to play during an participate in scheduled exercise emergency. Personnel shall participate in scheduled exercise and drills depending on availability. and drills depending on availability. Table 8-1, PERIODIC Post Accident Sampling Personnel Deleted. Not required post shutdown TRAINING OF EMERGENCY 58

Emergency Plan Before (Rev.33) After (Pending Revision Number) Reason for Change Section RESPONSE Chemistry personnel designated by PERSONNEL the Chemistry Supervisor to perform PASS samples On an annual basis, detailed training shall be provided on the purpose and applications of the Post Accident Sampling System with both a detailed review of applicable systems and a walkdown of the system equipment. 9.1, Reentrv,2nd ... The Ohio Radioloqical ... The Ohio Radioloqical Editorial - grammar paragraph Emeroencv Preoaredness Plan and Emeroencv Preoaredness Plan and the Ohio Emerqencv Operations the Ohio Emeroencv Operations Plan . Plan. 9.2, Recoverv, 2nd The Emergency Plant Manager, The Emergency Plant Manager, Reflect permanently shutdown and defueled condition. paragraph under the direction of the under the direction of the Emergency Director, will be Emergency Director, will be responsible at the site for responsible at the site for coordinating onsite recovery coordinating onsite recovery activities and the retum to normal activities and the retum to normal operations. status. 9.2.1.f Containment pressure is within Deleted. Reflect permanently shutdown and defueled condition. technical specifi cations. Containment pressure is not relevant in the permanently shutdown and defueled condition. 9.2.1.9 The reactor is in a stable safe The SFP is in a stable safe condition Reflect permanently shutdown and defueled condition. shutdown condition and long-term and long-term spent fuel cooling is core cooling is available as required. avaihbb as required. 59

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 9.2.2.b For events involving significant For events involving significant Reflect permanently shutdown and defueled condition. damage to plant systems required to damage to systems required to maintain operation of the plant, the maintain SFP cooling, the onsite onsite emergency organization, or emergency organization, or portions portions thereof, should be adequate thereof, should be adequate to to coordinate the necessary coordinate the necessary recovery recovery actions (e.9., for ALERT actions (e.9., for ALERT classifications). classifications). 9.2.2.c For events involving damage to plant For events involving significant Reflect permanently shutdown and defueled condition. systems required to maintain safe damage to the SFP or damage to shutdown of the reactor, a formal the spent fuel resulting in a Recovery Organization will be radiological release, a formal established to manage the recovery Recovery Organization will be actions (e.9., for SITE AREA or established to manage the recovery GENERAL EMERGENCY actions (e.9., for SITE AREA or classifications). GENERAL EMERGENCY classifications). 9.2.2,4th paragraph ln the final phase ofthe recovery ln the final phase ofthe recovery Reflect permanently shutdown and defueled condition. operations, a restoration program operations, a restoration program will begin. The overall purpose of the will begin. The overall purpose of the restoration program is to prepare for restoration program is to retum to resumption of full power operations. safe storage of spent fuel. This This program will include a detailed program will include a detailed incident analysis. Determinations incident analysis. Determinations will will be made as to the repair work be made as to the repair work required to perform needed required to perform needed modifications to plant equipment modifications to equipment and/or and/or operating procedures. procedures. 60

Emergency Plan Before (Rev. 33) After (Pending Revision Number) Reason for Change Section 9.2.3.d.2 Coordinate the development of plans Coordinate the development of plans Reflect permanently shutdown and defueled condition. and procedures in support of plant and procedures in support of SFP systems and operations activities. systems and aclivities. 9.2.3.e.3 Provide recommendations to the Provide recommendations to the Reflecl permanently shutdown and defueled condition. Outage Director regarding plant Outage Director regarding SFP operations-related aspects of the operations-related aspects of the recovery. recovery. Figure 9-1 Scheduling Manager block included Removed Recovery Advisor and Refl ec{ Post-Shutdown ERO organization RECOVERY reference to Recovery Advisor Resour[c]e Coordinator references. ORGANIZATION Material Manager block included FRAMEWORK reference to Resour[c]e Coordinator Appendix A, Off- 10. Containment Evacuation RA-EP- Deleted. Reflect permanently shutdown and defueled condition. Normal Occunence 02861 2.7,6.4.1 Editorial - remainder of listing was renumbered due to the two Procedure

11. Loss of Containment lntegrity deletions.

RA-EP-02865 2.7 Appendix A, NUREG 83 5.2.1, 5.3.1 - 5.3.3 83 5.2.',1,5.3.1 -5.3.2 Reflect Post-Shutdown ERO organization. Appendix C lnstitute of Nuclear Power Deleted. Davis-Besse will no longer be an operating plant and support Operations from INPO is not expected. Appendix F, title Davis-Besse Nuclear Power Station Davis-Besse Nuclear Power Station Reflect the change to post shutdown. (DBNPS) ERO On-Shift Staffing (DBNPS) ERO Post-Shutdown On-Analysis Report Shift Staffing Analysis Report 61

Attachment 2 Proposed Revisions to the DBNPS Emergency Plan, Revision 33 (Marked-up Version) (196 Pages Follow)

DBNPS Post-Shutdown Emergency Plan Revision 33TBD DAVIS.BESSE NUCLEARPOWER STATION POST-SHUTDOWN EMERGENCY PLAN

DBNPS Post-Shutdown Emergency Plan Revision 33TBD FOREWORI) 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 Post-Shutdown 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 33 TBD of the Post-Shutdown Emergency Plan meets the requirements of 10 CFR 50'5a(fl.ChangesmadeinRevision33IBu@onotdecreaseits effectiveness. The Plan has been revised in with NRC Safetv Evaluation ITBDI. The issuance and control of this Post-Shutdown Emergency Plan and activities associated with Emergency Response at the Davis-Besse Nuclear Power Station are the responsibility of the Si+e Plant Manager. Additions, deletions, or modifications to the Post-Shutdown Emergency Plan shall be approved by the Emergency Response Manegerr+he Manager and the General Plant Manager. It is intended that this Post-Shutdown Emergency Plan and the Emergency Plan Procedures be fully compatible with the applicable requirements for quality assurance set forth in the FENOC Nuclear Assurance Program Manual. The Emergency Response Manager is hereby assigned the responsibility for emergency preparedness operations with authority as established in this Post-Shutdown Emergency Plan and outlined above. Day-to-day maintenance and implementation of the Emergency Response Program is the responsibility of the Emergency Response Manager and the Emergency Response Section. Emergency Response Manager Date Direetot Site Perfermanee Imprevement Date General Plant Manager Date

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DBNPS Post-Shutdown Emergency Plan Revision 33TBD -ll-

DBNPS Post-Shutdown Emergency Plan Revision 33TBD Davis-Besse Nuclear Power Station Post-Shutdown Emergency Plan Revision 33 TBD Summar.v of Plan Chanees Full revision to address implementation of the Post-Shutdown Emersencv Plan. -Nelc\!.titLl har: urc Lrscd to idcnlili the changes. The changes to the on-shift and ausmented Emergency Response Organization staffing supoort the oermanent cessation ofpower operations ofthe Davis-Besse Nuclear Power Station and the Dermarlent removal offuel from the reactor vessel. tll

DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE OF CONTENTS Plan Section Topic Page I.O DEFINITIONS ..................... l-l 2.0 SCOPE AND APPLICABILITY 2-l 2.1 Site Description............. ..2-l 2.2 ., ., PopulationDistribution 2.3 Emergency Planning Zones ..2-3 2.4 Regulatory Requirements................. 2-3 2.5 Objectives of Emergency Response 2-4 2.6 EmergencyPlan lnterrelationships ..2-4 2.7 Emergency Plan Procedures, Station Procedures and Fleet Business Practice 2-5 2.8 Participating Governmental Agencies 2-6 I g.o suMMARy oF TnE posr-sHuTpowN EMERGENCv rLAN.......................3-l 3.1 Post-Shutdown Emergency Plan Steps........ 3-1 3.2 Emergency Organizations ............... 3.2.1 StateofOhio................ 3.2.2 Ottawa County, Ohio .......... ,.,.,..,3-2 3.2.3 LucasCounty,Ohio.......... ..................... 3-3 3.2.4 Erie County, Ohio 3.2.5 Sandusky County, Ohio .................. ........ J-J 3.2.6 State of Michigan.......... J-J 3.2.7 Federal Agencies.... 3.3 EmergencyCategories 3-4

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DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE OF CONTENTS Plan Section Topic Page 4,0 EMERGENCYCONDITIONS 4-l 4.1 Emergency Classification Levels (ECLs) 4-l 4.1.1 GENERAL EMERGENCY . 4-l 4.1.2 SITE AREA EMERGENCY 4-l 4.1.3 ALERT...... 4-l 4.1.4 UNUSUAL EVENT............. 4-l 4.1.5 RECOVERY 4-2 4.2 EMERGENCY CLASSIFICATION. 4-2 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)

                                                                                           ..4-3 4.4.1 MDeleted..                                                                    ..4-3 4.4.2                                                                                      -3 4.4.3                                                                                  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  Classif,,ing Transient   Events                                            ....4-5 5.0 ORGANIZATIONAL CONTROL OF               EMERGENCIES                  .....................5-I 5.1 DBNPS Organization.................                                                 .. 5-l 5.1.1 plan+EAqilitLManagement           and Administrative Organization...........5-l 5.1.2  Onshift Operations   Group.........                          ..................5-2

DBNPS Post-Shutdown Emergency Plan Revision 33IBD TABLE OF CONTENTS Plan Section Topic Page

5. 1.3 Normal plan+Eaqiliqlshift Staffing ........... 5-2 5.2 DBNPS Emergency Management................. ............... 5-4 5.2.1 EmergencyDirector 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 5-6 5.3 Onshift Emergency Response Organization .............. 5-6 5.3.1 ShiftManager................ 5-6 s.3.2 @ 5-7 5.3.3 Deleted. 5-7 5.3.4 Security Shift Supervisor............. 5-7 5.3.5 Onshift Maintenance Support 5-7 5.4 Onsite Emergency Response Organi2ation........................ 5-8 5.4.1 Overview... 5-8 5.4.2 Direction and Coordination..... 5-9 5.4.3 ControlRoom..... 5-9 5.4.4 Technical Support Center (TSC) Organization ..... 5-9 5.4.5 Operations Support Center (OSC) Organization... 5-r:I3 5.5 Near Site Emergency Response Facility...... 5-] 5 l6 5.5.1 Overview... 5-r5i6 5.5.2 Emergency Operations Facility (EOF) Organi2ation...................5-l(rl7 vl

DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE OF CONTENTS Plan Section Topic Page 5.6 Joint Information Center (JIC)............. s-l8Le 5.7 Corporate Assistance Center (CAC).... 5-,1+19 5.8 Supporting Emergency Organizations ...................... s-1e21 5.8.1 Letters of Agreement ............... 5-1e? I 5.8.2 Medical Emergency Response Organization 5-1921 5.8.3 Government Agency Support...... 5.8.4 Other Support Organizations ............ ..s-?810 6.0 EMERGENCY MEASURES ...,....... ........6-1 6.1 Activation of the Emergency Response Organizations................. ........6-1 6.1 .l 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 vll

DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE OF CONTENTS Plan Section Topic Page 6.3 Mitigative Actions....... 6-8 6.4 Protective Actions....... 6-8 6.4.1 planrEaqil=qlsite-Protective Actions 6-8 6.4.2 Offsite Protective Actions....... ...................6-10 6.4.3 Use of Onsite Protective Equipment and Supplies..........................6-l l 6.4.4 Contamination Control Measures 6-1 l 6.4.5 Ingestion Pathway Control Measures ..... 6-l I 6.5 Aid to Affected Personnel......... ..6-11 6.5.1 Emergency Personnel Exposure.... 6-l I 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 MedicalTreatment 6-14 7.0 EMERGENCY FACILITIES AND EQI.IIPMENT 7-l 7.1 DBNPS In-Plant Emergency Facilities ....7-l 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 Alarms .....7-9 7.8 Prompt Notification System ..7-10 7.9 AssessmentFacilities ..7-tt vlll

DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE OF CONTENTS Plan Section Topic Page

7. I 0 Protective Facilities and Equipment ..... ....7-17 7.ll First Aid and Medical Facilities.. ....7-18 7.12 Damage Control Equipment. ....7-18 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 Emergency Response Manager 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-L 9.1 Reentry...... 9-r 9.2 Recovery 9-2 lx

DBNPS Post-Shutdown Emergency Plan Revision STBD 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 FirstEnergy Corporation - 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 Post-Shutdown On-Shift Staffing Analysis Report x

DBNPS Post-Shutdown Emergency Plan Revision 33TBD LIST OF TABLES Plan Tables Title Page 1-1 Acronyms.. l-+12 t-2 Communications Test Frequencies 2-l Functional lnterrelationships of Response Organizations ............. 3-l Emergency Categories and the Degree of Participation by Various Groups.. 3-5 4-1 Operating Mode Applicability 4-4 5-l Manpower, Location, and Response Considerations for Emergencies............ 5-3+34 6-l PAGs for the Early Phase of a Nuclear Incident ................... 6-l 5 6-2 Recommended ProtectiveActions. ................... 6-16 6-3 Representative Shielding Factors from Gamma Cloud Source..... ................... 6-l 7 6-4 SelectedShieldingFactorsforAirborneRadionuclides............... ....6-18 6-5 Representative Shielding Factors for Surface Deposited Radionuclides ......... .............6-1 9 6-6 Guidelines for Protection Against Ingestion of Contamination... 7-l Radiation Monitoring Instruments and Equipment ...................... 7-19 8-l Periodic Training of Emergency Response Personnel 8-10 xl

DBNPS Post-Shutdown Emergency Plan Revision STBD LIST OF FIGURES Plan Figures Title Page 2-l DBNPS General Site Location.......... 2-8 2-2 DBNPS Site Annual Wind Distributions at the 10 Meter Level ..........2-9 2-3 DBNPS l0-Mile Emergency Planning Zone... 2-10 2-4 DBNPS 50-Mile Emergency Planning Zone... 2-tt 5- I Onshift Emergency Organization .................... 5-F31 5 -2 Emergency Response Organization ................. 5-343tt 6-l Summary of Typical Emergency Measures..... 6-22 6-2 EmergencyNotification 6-26 6-3 Offsite Emergency Evacuation Routes............ 6-28 7-l Emergency Facilities by General Location ..... 7-21 9-l Recovery Organization Framework ...9-7 xll

1-l DBNPS Post-Shutdown Emergency Plan _Revision 33TBD I.O DEFINITIONS Listed below are terms and their definitions as used in the Post-Shutdown 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 andl/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 plan+faciliqlstatus information to individuals who are knowledgeable of, and responsible for engineering and management support of reaeterSl_P-operations in the event of an emergency sifuation. 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 Facilitv 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. t.9 Compensatory Indications Plant Process Computer, SPDS, and PI Data (Process Book). I.IO 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).

t-2 DBNPS Post-Shutdown Emergency Plan _Revision 33TBD in p+an+Aei+i -greenei+ie*s-H4t.l I Area An area where removable contamination exists at levels in excess of 1000 dpm/lO0cm2 beta gamma or 20 dpm/100cm2 alpha. +-+31.12 Conhol 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. }Jal.l3 Controlled Rele Any release of radioactive material from Davis-Besse Nuclear Power Station to the environment, which is planned, deliberate, monitored and regulated. HSl.ta Oesign Basis Ac 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. 1J6t.t S Oose 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. +a+11.16 Drill A supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. Hl.17 EMERGENCY ACTION LEVEL GAL) A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plan+faqi_lil1in a given emergency classification level.

1. 1.18 EMERGENCY SIFICATION LEVEL GCL)

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 severiqz, are: o Unusual Event (UE)

       . Alert (A) r    Site Area Emergency (SAE) o   General Emergency (GE)

H01.19 Emersencv Facilitu GOF) An area located at 1240 South Main Street, Lindsey, Ohio, which is equipped to facilitate the control and coordination of emergency activities and assessments.

l-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD he teu'Pressure lqieetien, High Pressure gZt.20 Bmergency Ope An offsite location used by State, County and other government agencies and organizations to perform radiological assessment and to coordinate offsite activities. l=+3t.Z t Post-Shutdow The document, which describes the Company philosophy and organization for implementatiqnng of regulations dealing with a response to a radiological accident at the Davis-Besse Nuclear Power Station. 91.22 Plan Procedures Those procedures which implement the Post-Shutdown Emergency Plan and are maintained by the Emergency Response Section. They include the Emergency Plan Implementing Procedures, Off-Normal Occurrence Procedures, and Administrative Procedures. 91.23 Plannins Zones Two zones established around a nuclear power station in which predetermined protective action plans are needed. One zone, with a radius of l0 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. wl.24 EPA ACTTON GUIDELINES Environment Protection Agency Protective Action Guidelines. The EPA PAGs are expressed in terms of dose commitment: I 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. +71.25 Essential Personnel Those assigned specific emergency response duties as identified in the Post-Shutdown Emergency Plan. W1.26 Exclusion Area The area surrounding the plan+faqiliglin 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 from720 meters (approximately ll2 mile) to approximately 1 mile. W\.21 Exercise An event that tests the integrated capability and a major portion of the basic elements within the Post-Shutdown Emergency Plan.

t-4 DBNPS Post-Shutdown Emergency Plan Revision 33TBD I.3028 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. ruD The term applied te a steam generater that has a steam leak en the seeendary side ef 1.,1229 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 iflarge quantities ofsmoke and heat are observed. I il fi$Sl0N+*Q:l;)tJ@Aprc'dete+n+ireelo*itc+;peci$e, observalale tlrresholJ-indioatiflg+h lss r?otenrial "loss sfal+si;ir+n prodr+e{rarliei 1.3-1]O 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. 1.353 I 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 veriS, the capability to respond to the accident scenario. (10CFR50, Appendix E, IV.F.2.a) 1.:l6ll 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. I..]7].] 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.,1iql,l High Radiation Area Any area, accessible to individuals, in which radiation levels could result in an individual receiving in excess of0.1 rem in one hour at 30 cm from the radiation source or from any surface the radiation penetrates.

l-5 DBNPS Post-Shutdown Emergency Plan _Revision 33TBD r.-3eis HoSTAGE A person(s) held as leverage against the station to ensure that demands will be met by the station. 1.,1$36 HOSTILE ACTION An act toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satis$z the overall intent may be included. HOSTILE ACTION should not be construed to include acts ofcivil disobedience or felonious acts that are not part ofa 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). 1.1t37 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..3E 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. 1.439_ TMPEpE(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.((:iQ INDEPENDENT SPENT FUEL STORAGE INSTALLATION flSFSI) 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.-15.,1 I 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..1 {r.12. INITIATING flc) An event or condition that aligns with the definition of one of the four emergency classification levels by virtue ofthe potential or actual effects or consequences.

l. i ,.14i International Great Lakes Datum A place ofreference 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 ..13,1.-l Joint Information Center

t-6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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..1945 Loss A state of inoperability in which Functional and Operable status cannot be maintained. 1.5$46 Low Population Zone The unrestricted area outside the OWNER CONTROLLED AREA, encompassed within a radius of 2 miles (approximately 3200 meters) from the site. l.sl4f MATNTAIN Take appropriate action to hold the value of an identified parameter within specified limits. 1.5248 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). 1.5149 Modes of Discharge Discharge of radioactivity to the ground surface, surface water, atmosphere, or any combination thereof. 1.5-1i5Q News Statement A detailed statement in printed format intended for public knowledge containing an announcement, supporting information, and usually some background information. 1.5 15 Non-essential Personnel Personnel who are not pre-assigned specific emergency response duties. 1.56!2 Normal Levels The highest reading in the past twenty-four hours excluding the current peak value. 1.5151 Nuclear Group The functional area of the Company which operates and maintains all nuclear generating facilities owned by or licensed to the Company. l.i.!5,,1 Offsite Any area outside the OWNER CONTROLLED AREA. 1..,!5) Onsite The area within the OWNER CONTROLLED AREA. 1.605 (r Operable/Operabilitv 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 affendant 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).

t-7 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 1.il51 Operations Support Center A location within the PROTECTED AREA where emergency response teams are assembled, briefed and coordinated during an emergency. I.858 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. 1.6359 Partial Paticipation 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.o) L6.160 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.]. 1.65(l 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: a Whole body external exposure to gamma radiation from the radioactive plume and from deposited material, a Inhalation exposure from the passing radioactive plume. 1.66(Q Population At Risk Those persons for whom Protective Actions are being or would be taken. 1.6163 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. l.(i(r4 PROJECTILE An object directed toward a nuclear power plant that could cause concern for its continued operab il ity, rel iabi I ity, or personnel safety. l.i;965 PROTECTED AREA An area that normally encompasses all controlled areas within the security protected area fence.

t-8 DBNPS Post-Shutdown Emergency Plan _Revision 33TBD 1.7$00 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. 1.7161 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. 1.7"6_8 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 I hour at 30 cm from the radiation source or from any surface the radiation penetrates. 1.73f9 Radiation Work Permit A document which gives radiation protection requirements, authorization to enter the radiologically controlled area, and permission to receive radiation dose. 1.U7t) Radiologicall), 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 1.1r1 ] 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. l .]6 Dnc r\I- S ^heuld be eensidered intaet when the Re S pressure beundarr- is in

                   ^ ^TTheRe its nermal eenditien fer the eeld shutdou'n mede ef eperatien (e,9,; ne freeze seals er nezz+e+amd 1.1172 Recovery Actions Those actions taken after an emergency to restore the station as nearly as possible to pre-emergency conditions.

+ .;8 1.191i Release A radiological release (airborne or liquid) to the outside environment attributable to the emergency event. I.8+}71 RESTORE Take the appropriate action required to return the value of an identified parameter to the applicable limits. I iil lit l'll:l(l I) The eenditien ef a stearn generater in t'hieh primar) te seeendar)' leakage is ef suffieient

t-9 DBNPS Post-Shutdown Emergency Plan _Revision 33TBD 1.{*27) Safetv Parameter Display System (SPDS) - A computer system that acquires and displays planffaqi!$Ldata. This system provides data to Operator Aids-anC+heme+geny 1,83 SAFETY SYSTEMA system required for safe plant eperatien; eeeling dervn the prant ine eendi+ieq I.IJ476 SECURITY CONDITION Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threaVrisk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. LS577 Shift Manager's Office A facility that is located within the Control Room envelope and irynefbe used by the Emergency Assistant Plant Manager during emergency conditions to observe and provide guidance to the Shift Manager for direction and control of ir+plan+fagjl!fi activities. 1.8678 SrTE 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: l) 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. 1.1]:J"19 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. l.t{8$0 State The State of Ohio. 1.8'.)8 I Technical Support Center (TSC) An area within the OWNER CONTROLLED AREA, which has the capability to display and transmit planffaqilj-qlstatus information to individuals who are knowledgeable of, and responsible for engineering and management support of reaetepSEP operations in the event of an emergency situation. l.(l(iil2 Uncontrolled Release Any release of radioactivity from Davis-Besse Nuclear Power Station to the surrounding

l-1 0 DBNPS Post-Shutdown Emergency Plan Revision 33TBD environment which can be described by any one or combination of the following terms unplanned, unintentional, and unregulated. l.+l8l LTNISoLABLE An open or breached system line that cannot be isolated, remotely or locally l.q2E4 UNPLANNED A parameter change or an event that is not l) the result ofan intended evolution or 2) an expected planffaStlql_response to a transient. The cause of the parameter change or event may be known or unknown. 1.q385_ UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation of the level of safety ofthe 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. l.e'+!0 VALID An indication, report, or condition, is considered to be VALID when it is verified by: l) an instrument channel check, 2) indications on related or redundant indicators, or 3) by direct observation bV ptanrfaqilislpersonnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. l.e:87 VISIBLEDAMAGE 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. l.q6[i8 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 Post-Shutdown Emergency Plan _Revision33TBD 1.93 T'NUSUAL 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 funher degradation of safety systems occurs. 1.94 VALID An indication, report, or condition, is considered to be VALID when it is verified by: l) an instrument channel check, 2) indications on related or redundant indicators, or 3) by direct observation bV plan+faqiliqlpersonnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. 1.95 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. 1.96 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.

t-12 DBNPS Post-Shutdown Emergency Plan _Revision 33TBD TABLE 1.1 ACROI{YMS AC Alternating Current ATSC Alternate Technical Support Center ALARA As Low As is Reasonably Achievable y\PRM- Average Peu'er Range Meter ARM Area Radiation Monitor r\TWS Antieipated Transient Witheut Seram B&W Babcock and Wilcox BWR Beiling Water Re CA Controls Area (in control room) CAC Corporate Assistance Center CAM Continuous Air Monitor CANS Computerized Automated Notification System CAS Central Alarm Station CDE Committed Dose Equivalent CE Combustion Engineering CFH Certified Fuel Handler CFR Code of Federal Regulations CNRB Company Nuclear Review Board CRM Containment Radiation Monitor in CTRM Control Room cpm counts per minute DADS Data Acquisition and Display System DBAB Davis-Besse Administration Building DBABA Davis-Besse Administration Building Annex DBNPS Davis-Besse Nuclear Power Station DC Direct Current DFSF Dry Fuel Storage Facility DOE Department of Energy DOT Department of Transportation DPM Decades Per Minute dpm disintegration's per minute E&C Electrical and Controls EAL Emergency Action Level EAS Emergency Alert System Cooling Systern ECL Emergency Classification Level ED Emergency Director

1-13 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 1-1 ACROI\TYMS EEC Energy Education Center EMA Emergency Management Agency ENS Emergency Notification System (NRC "red phone") EOC Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure EPZ Emergency Planning Zone ERO Emergency Response Organization FSF Fngineered Saft FSW Emergene)'Ser ffi FBI Federal Bureau of Investigation FE FirstEnergy Corporation FEMA Federal Emergency Management Agency FENOC FirstEnergy Nuclear Operating Company FSAR Final Safety Analysis Report GE General Emergency HPI Ftrigh P"essure trdeetien HPCI High Pressure eeelant Itieetien HPSI High Pressure SareB'lqieetien I{PN Health Physics Network IC Initiating Condition I&C Instrument and Control IGLD International Great Lakes Datum ISFSI Independent Spent Fuel Storage Installation JIC Joint Information Center Keff Effective Neutron Multiplication Factor LCEMA Lucas County Emergency Management Agency LCO Limiting Conditions for Operation LDE Lens Dose Equivalent Hieensee Event Repeft

                     ,e Safety ldeetien mR       milliRoentgen

t-14 DBNPS Post-Shutdown Emergency Plan _Revision 33IBD TABLE 1-1 ACROI{YMS MSSV l\4ain Steam Safery V H ion MW Megawatt MWe Megawatt electric MWt Megawatt thermal NCO Non-Certified Operator NEI Nuclear Energy Institute NtrSP Natienal Envirenmental Studies Prqieet NOAA National Oceanographic and Atmospheric Administration NORAD Nefth ytmeriean Aerespaee Defense eemmand NOUE Notification Of Unusual Event NPP Nuclear Power Plant NRC Nuclear Regulatory Commission NSSS Nuelear Steam Supply System NUMI\RC Nuelear Management and Reseurees Ceuneil OBE Operating Basis Earthquake OCA Owner Controlled Area OCEMA Ottawa County Emergency Management Agency ODCI!{/ODAM OffsiteDoseCalculation(Assessment)Manual OEMA Ohio Emergency Management Agency ORO Offsite Response Organization OSHP Ohio State Highway Patrol OSC Operations Support Center PA Protected Area PAF Primarr'Aeeess F PAG Protective Action Guide PASS Post Accident Sampling System (see ARCSS) PNS Prompt Notification System (siren system) e PR4/PS,\ Prebabilis PWR Pres'urized Water Reaeter PSIG Pounds per Square Inch Gauge R Roentgen RCA Radiologically Controlled Area Rele Reaebr eere Is in ReS Reaeter eeelarrtSysterrr REM Roentgen Equivalent Man REMP Radiological Environmental Monitoring Program RETS Redielegieal E iens RMT Radiation Monitoring Team RP Radiation Protection

l-l 5 DBNPS Post-Shutdown Emergency Plan _Revision 33TBD TABLE 1-1 ACROIYYMS RTL Radiological Testing Lab RVttrS Reaeter Vessel tevel Indieating S)'stern Rr#eU Reaeter Water eleanup RWP Radiation Work Permit SAS Secondary Alarm Station SCBA Self-Contained Breathing Apparatus SDE Shallow Dose Equivalent P F SPDS Safety Parameter Display System SSE Safe Shutdown Earthquake STr\ Shift Teehnieal \dviser TEDE Total Effective Dose Equivalent TRM Technical Requirements Manual TSC Technical Support Center VPF Visiter Preeessing Faeilib' UE Unusual Event USAR Updated Safety Analysis Report VDC Volts DC WE Westinghouse Electric WOG Westinghouse Owners Group

t-16 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE I.2 COMMTTNICATIONS TEST FREOUENCIES 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-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 2.0 SCOPE AND APPLICABILITY The Davis-Besse Nuclear Power Station Post-Shutdown 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 Post-Shutdown Emergency Plan is a detailed expansion of the Updated Safety Analysis Report, Section 13.3. It is intended to satisfu 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 ofNUREG 0654/fEUa REP. 1, Rev. l, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. This Post-Shutdown Emergency Plan is not the primary working document to be used during an emergency. The purpose of the Post-Shutdown Emergency Plan is to describe the program established at DBNPS to satisfu regulatory requirements and to safeguard the public and plan+ facilit-v 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@apressurizedlightwaterreactorsteamsupplysyStem furnished by the Babcock & Wilcox Co. (now AREVA NP) to generate approximately 930 MWe. The reactor design core power is-rvef28l7 MWt. The reactor permanentllz ceased power operations on [DATEI and was permanentl]z defueled on [DATEI. Spent Fuel is stored in the Spent Fuel Pool (SFP) and the Independent Spent Fuel Storage Installation (ISFSI). 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 l4 feet above the existing grade elevation to an elevation of 584 feet lnternational 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 Post-Shutdown Emergency Plan Revision 33TBD 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 Pon 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 l0 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 System's 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.-I, Appendix 4. The near-site population is distributed from the southeast to the west northwest. The total permanent population in the l0-mile area surrounding DBNPS, based on 2010 Census information is 20,403 people. Approximately 89%o 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 l0 mile, and l0 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/IEMA Rev.-l, Appendix 4. TheEPZ permanent resident population is reviewed annually. If at any time during the decennial period theEPZ 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-mileEPZ to increase by 25 percent or 30 minutes, whichever is less, from the currently NRC approved or updated ETE, FENOC 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

2-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FENOC determines the criteria for updating the ETE have been met and at least 180 days before 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 5O-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 l0-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-mileEPZ is direct exposure from a passing plume and/or inhalation of radionuclides from the plume. This l0-mile EPZis 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 lO-mile and 5O-mile EPZs. 2.4 RegulatoryRequirements 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 Post-Shutdown Emergency Plan Revision 33TBD 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. l, 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. 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 Post-Shutdown 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.

o

b. To establish procedures to identifu and classiff 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 EmergencyPlanlnterrelationships 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 Post-Shutdown Emergency Plan Revision 33IBD 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.s 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., REVA NP, Bechtel, etc.). 2.7 Emergency Plan Procedures. Station Procedures and Fleet Business Practice Detailed Emergency Plan Procedures direct the implementation of this Post-Shutdown Emergency Plan. Detailed Station procedures prescribe appropriate courses of action necessary to place the planfacriliqlin 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 Post-Shutdown Emergency Plan Revision 33TBD 2.8 ParticipatingGovemmentalAgencies Participating govemmental 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 CountSr, The Lucas Countv 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 Post-Shutdown 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 Post-Shutdown Emergency Plan Revision 33TBD Table 2-l FUNCTIONAL INTERRELATIONSHIPS OF RESPONSE ORGANIZATIONS F t-o E. o-E. o-F t F t Ft o o- U =' o (L o o- o o- C' o-(L f o- o- = U) = a U=) =) U _.t IJ.J tlrJ J d LU I o LU o UJ = (9 o F o J E c/) LU LL =U L DAVIS-BESSE RESPONSE FUNCTION RESPONSE ORGANIZATION(S) PlastSEL 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 Emergency Operations Facility Warning R A A Control Room Notification & Communication A R A A Control Room/EOF Public lnformation R A A Joint lnformation 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 Securig Transportation R Emergency Operations Facility Radiological Exposure Control A R A Emergency Operations Facility LEGEND: R=Task Responsibility A=Task Assistance LOCAL STATE FEDERAL ENGINEERING SUPPORT Ottawa County EMA Ohio EMA US NRC Region lll Areva, NP 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 lnsurers 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 Post-Shutdown Emergency Plan Revision 33IBD Figure 2-1 DBNPS General Site Location t"{el 4a d DAVI$BBSSE rcRT BOWLING GREEN NORW,TLK

2-9 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure2-2 DBNPS Site Annual Wind Distributions At the 10 Meter Level N NN}I NNI NW NE cALr,,l l/1l 0.07 E PERCENT SH 5tr SF SSt,I SSE

    }ffi+(}AAAfl urNo sptru     (t'rr,rl)             S Wruf         Dlllr,C'lt6N t,plpr,l Ncy     (X)

DAV I S* I]ESSH ANNUAL 20 7 T 1OM I."EVEt

2-10 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure 2-3 DBNPS lO-Mile Emergency Planning Zone Wrx Sirtr bLil A I R c a ta I D SOUTf,EA8E a tla ItLAl{D P a f 11 G a I a l I a a I I I I bbra a &r aaa a N LA-IiID r 3 i t I ROCE Ir 7tI I irl aa aa ta a aaartty.aal a ,t"t' a I r I oix t!l L I a I

                                  )I                         8 a

l a 5 I a I a O srt{DusKI SAy { araaarrr a K J

2-tt DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure2-4 DBNPS 50-Mile Emergency Planning Zone LAKE ST CLAIR a 1 WINDSOR ANNARBOR. N 50 20 ERIE MICHIGAN OHIO STA PORT LORAIN a

                                                                . ELYRIA a

a TIFFIN .

3-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 3.0

SUMMARY

OF T}IE POST-SHUTDOWN EMERGENCY PLAN The DBNPS Post-Shutdown 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-l and other documents. The Post-Shutdown Emergency Plan will be put into effect whenever a radiological emergency or other potentially hazardous situation is identified. The details of the Post-Shutdown Emergency Plan Procedures are not included herein, but a description ofthe scope ofthe 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 Post-Shutdown 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 ofthe general public. 3.1 Post-Shutdown Emergency Plan Steps In general, the Post-Shutdown 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 0 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 EmergencyOrganizations 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 ifthe situation dictates. An individual with the authority and responsibility to initiate any emergency actions under the provisions of this Post-Shutdown Emergency Plan, including the release of information to the publiclmedia, is onsite at all times. The Shift Manager assumes this authority by becoming the Emergency Director upon initial classification of an emergency. If the Shift Manager cannot assume these duties, authority is delegated to another qualified mernber of tl.," on-rhift rtuf erdr. The Emergency Plant Manager or Emergency Assistant Plant Manager may assume

3-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD the Emergency Director position upon arrival in the Control Room or TSC. The Emergene).Direegr duties frem the @ThedesignatedEmergencyDirector,uponarrivalinthe Emergency Operations Facility (EOF) or Technical Support Center (TSC), will assume this authority. The eperatir+g a!::shift crew is responsible for implementing emergency procedures in accordance with assigned response functions. Emergency response functions are also assigned to off-shift planffasdtqt-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. ln 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 Countv 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.

J-J DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 Countv 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 Sanduslcy Coun8 Radiological Emergencv 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 notifu 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 Post-Shutdown Emergency Plan Revision 33TBD 3.2.7 Federal Agencies

a. U.S. Nuclear Regulatory Commission (NRC), Region [II, 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 EmergencyCategories Emergencies are grouped into four categories. From least to most severe they are: 3.3.1 UNUSUAL EVENT 3.3.2 ALERT J.J.J 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.

3-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 3-I EMERGENCY CATEGORIES AND THE DEGREE OF PARTICIPATION BY VARIOUS GROUPS Participation Necessity By Various Organizations for Emergency Protective Actions Mitigative DBNPS Offsite Category Onsite I Offrit" Actionsl 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 tAction might include local fire support, ambulance service, medical assistance, or radiological assessment. '?Notification Status: Organization informed of situation onsite. 3Standby Status: Organization staffs preplanned centers, establishes communications, and assembles emergency teams, as required.

4-1 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 4.0 EMERGENCY CONDITIONS 4.1 Emergency Classification Levels (ECLs) The Davis-Besse Nuclear Power Station Post-Shutdown 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 identiffing abnormal conditions and then comparing them to INITIATING CONDITIONS (ICs) through EMERGENCY ACTION LEVELS (EAL) and F:ssien Preduet B hreshold values as discussed below. When multiple EALs are met, event declaration is based in the highest ECL reached. Post-Shutdown 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: l) 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 LINUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation ofthe level ofsafety 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 Post-Shutdown Emergency Plan Revision 33TBD 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 Post-Shutdown Emergency Plan. 4.2 EMERGENCY CLASSIFICATION The Davis-Besse Nuclear Power Station maintains the capability to assess, classifr, and declare an emergency condition within I 5 minutes of the availability of indications that an EAL has been exceeded. The l5-minute criterion commences when plan#ac:i.liglinstrumentation, plan#fac:iliry alarms, computer displays, or incoming verbal reports that correspond to an EAL first become availabletoany@. 4.3 INITIATING CONDITION (ICs) The INITIATING CONDITION (IC)-ad, EMERGENCY ACTION LEVELS (EALs) an4+he+issien @ix-withtheirrelatedbasisinformationarelocatedinAppendixEofthe Post-Shutdown 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 offour 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 Fissien Preduet Barrier Degradat'en 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

4-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 Appendix E, DBRM-EMER-1500 A, Davis-Besse Emergency Action Levels Basis Document. 4.4 EMERGENCY ACTION LEVELS (EALs) EMERGENCY ACTION LEVELS (EALs) are predetermined, site specific, observable conditions within the ICs that place the state of the plan+faciliglin a given ECL (Reference Post-Shutdown Emergency Plan, Appendix E). EALs are individually identified by the IC identification code followed by the EAL number, such as RGl.l for major effluent release or HU3.1 fortornado. in varieus Eets, The first trn'e letters simply identi& the -artieular barrier by abb*eviatien, The letter in the FPB identifieatien eede asseeiates it with a partieular FPB reeegnitien eateger)', The FPB identifieatien e 4.4.1 MDeleted 4.4.2 Deleted Fissien Produet B iefi-or fevfy; For EALs that contain time imbedded criterion, the Emergency Director 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 Post-Shutdown Emergency Plan Revision 33IBD 4.4.3 @Deleted TABTE4I R,ee+i+iry  %-Ra+ed A*+ae4eelafl+ A4ode esna+isnJ<ef{ Thermal Power* Tmpratu+e D+{#er@ion >4rqg

• NIA 2)S+artup - 0,99 4% N/A 3)#+anCby <459 N/A >+80e-p 4)-H+Sffi # N/A ry s)ffi#n <499 N/1\ < 2000 F 6)-Refile+in ene er mere ve'sel head elesure belt+less than fullv tensiened, DIDef+eled e is ehange in eperatinglnedefullew rr'ill be evaluated en the rnede ef the plant at the time the subsequent events eeeur, 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 Director 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 Director, an IMMINENT situation is at hand, the

4-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 I-INUSUAL EVENTS, ALERTS, and certain SITE AREA EMERGENCIES causing no long term planfasifiqldamage appears to be the best choice. Downgrading to lower emergency classification levels adds notifications but may have merit under certain circumstances. Figure 6-l illustrates the options for downgrading or termination of events based on current planfaSillq{_conditions. Recovery phase is discussed in Section 9.2. 4.4.6 Classiffing 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 @fagiliqldamage occurred while the mitigative actions were being taken. In some situations, this can be readily determined, in othersituations,furtheranalysesaybenecessary.Classifr 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 classifuing 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 plantfacriliry, declaration requirements should not be considered to be met when the conditions are apart of the designed planfaqiliry response, or result from appropriate operator actions. There may be cases in which a planrfaqililLcondition 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 ofNUREG-1022,Event Reporting Guidelines, 10 CFR 50.72 and 50.73, should be applied.

5-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES In planning for emergencies the availability of the normally present eperating-anthiflstaffl 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. These individuals will be capable of: {l) determining that an emergency exists, (2) providing initial classification and assessment, (3) promptly notifuing 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 a SITE AREA EMERGENCY or a GENERAL EMERGENCY, this will result in the mobilization of all personnel resources of the Company, under the direction of a Senior Company Officer. This section of the Post-Shutdown 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) 5.8 SupportingEmergencyOrganizations 5.1 DBNPS Organization and engineering activities at DBNPS are under the control ofthe . DBNPShasengineeringservicecontractswiththe s"ppMth-Architect-Engineer. Organizational structure and communication arrangements exist to assure that these services are available and can be obtained in a timely manner.

5. I . 1 plan+EAqiliqlManagement and Administrative Organization The General Plant Manager directs and supervises all eperati+g;administrative, technical and maintenance activities in connection with the continuous, efficient and safe at the DBNPS.

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

5-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 5.t.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 NI8.1, and includes both management and operatisrc+g personnel. Figure 5-1, Onshift Emergency Organization, shows the functional levels. iens, These persennel form the initial nueleus staff ef the OSe , Other continuous duty, 24 hours-per-day organizations include PlanlOperations, ehe++ist46-Radiation Protection and Security. Additienal-Maintenance personnel and the various Engineering organizations are onsite during normal work hours, Monday through Friday, excluding holidays. 5.1.3 Normal ptan+EasiliqlShift Staffi ng The plant-s-fagiliry i operating staff meets or exceeds the requirements of Technical Specification 5.2.2 . Table 5-r MANPOWE& LOCATION, AND RESPONSE CONSTDERATIONS FOR EMERGENCIES, A. ONSHIFT MINIMUM STAFFTNG REQUIREMENTS describes the minimum on shift staffing utilized to support the Post-Shutdown eEmergency pfllan. In addition, the pknffaqiliOlis continuously r+anneS$taflfigilwith a minimum shift complement consisting of the following: 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 planffaqiliqlmanagement24 hours a day.

Table 5-1 specifies minimum shift requirements as prescribed by NUREG-0654, Table B-1. The Shift Manager directs the onshift personnel opera+in+h-s+ation-and verifies that their work is performed according to approved procedures. Ultimate authority for directing all phases of plar++SIL operations always lies with the Shift Manager. The Shift Manager becomes the Emergency Director upon classification of an emergency at DBNPS.

                                                  , who isqgs assigned to each shift{u+ing pe{irerlnedes, assists the Shift Manager by following his directives i{i-super+isi*g

5-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD emp+eyeesngaged in controlling the e-eratiens ef the Nuelear Steam Su-ply station equipment. During an emergency, the may also dire+-ery+efes+e-function as emergency maintenance personnel or to assist fire brigade team members. The An appropriately qualified {JnitSupe*iserNon-Certified Operator could assumes the role of Shift Manager, including Emergency Director duties, should the Shift Manager become incapacitated. inatien ef maintenanee sehedules; establishment ef shert term ehieetives fer plant Teehnieal Adviser) alse prevides the additienal teehnieal and analltiealea^abiliB' teehnieal assistant te the Shift Nteneger in analyzi Adviser) ma)'serve a Unit Superviser are ineapaeitated, Under eertain eireumstanees; the Shift Fneineer (Shift Te ior 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 Post-Shutdown Emergency Plan Revision 33TBD 5.2 DBNPS Emergency Management In the event of a declared ALERT or higher level emergency, the Onsite and Near Site Emergency Response Organization (ERO) shall be activated. The individuals responsible for managing the emergency are the Emergency Director, Emergency Offsite Manager, Emergency Plant Manager and the Company Spokesperson. 5.2.1 EmergencyDirector

a. The Emergency Director is the senior individual in the onsite ERO responsible for the coordination of the overall response to any emergency at the DBNPS. During such an emergency, the Emergency Director will coordinate and direct the emergency response from the Control Room, or the Emergency Operations Facility (EOF).

The following are non-delegable responsibilities of the Emergency Director: I Emergency Classification 2 Offsite Protective Action Recommendation

                    )       Compliance with station procedures 4        Safety and well being of station personnel 5        Ordering a station general evacuation Responsibilities that the Emergency Director may delegate to the Emergency Plant Manager only are:

I Emergency dose authorizations in excess of 10 CFR 20 limits, and 2 Onsite administration of Potassium Iodide (KI).

b. Reporting directly to the Emergency Director are:

l. Emergency Offsite Manager

2. Emergency Plant Manager

3. CompanySpokesperson iso+

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

l. Emergency Plant Manager

2. Emergency Assistant Plant Manager a

J. Shift Manager

4. Unit SuperviserAnother qualified on-shift individual 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

5-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 or TSC. 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.

5.2.3 Emergency Plant Manager The Emergency Plant Manager is the senior individual responsible for the coordinationandconductofallactivitiesassociatedwith@ of spent fuel in the SFP, planfacriliqlassessment, emergency classification associated with pkn+faqilislparameters, and onsite actions taken to mitigate the emergency situation. The Emergency Plant Manager reports to and advises the Emergency Director on planffacriLiqlstatus 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.

5-6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 5.2.4 Company Spokesperson The Company Spokesperson is responsible for the overall operation of the Joint Information Center (JIC), conferring with the Emergency Director concerning planlfuilqlstatus, 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 5.2.5 The Emergeney Direeter Advisor is respensible for aeeempanying the Emergeney nireeter during it+ing-an-awarenss ef the present emergeney situatien; rvhile antieipating pessible ehanges, Persenal ief the Fmergeney Direeter fesponss; 5.3 Onshift Emergenclz Response Organization Onshift Emergency Response Organization personnel are adequately trained to recognize, classiff, notiff, 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 Director. The Shift Manager supervises the following activities:

a. The timely assessment of planrfaqilllstatus.

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.

(} b' Authorization of emergency radiation doses.

5-7 DBNPS Post-Shutdown Emergency Plan Revision 33TBD s.3.2 @ nuring eewer oeer#i The Unit Superviser will imrnediately assume tlre duties and autherities ef the Shift Manager; ineluding Bmergeney Direetor duties; if the Shift Manager beeemes inaeaer+ad 5.3.3 Deleted is

     @atien;                             and aetiens neeessar,'te terminate er mitigate iof,'

The Shift Engineer (Shift Teehnieal r\dviser) will assume the rele ef Emergeney in funetien 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 Emergency Security Manager and interfaces with the OSC Manager and the OSC RP Coordinator. 5.3.5 nuring r+oflnal pwer o iefls'

5-8 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 5.4 Onsite Emergenclz 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 organizationisultimatelytheresponsibilityofthe@ Plant Manager. However, the Emergency Response Manager 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 mafi+ine$4ffi!&to satisft 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 pr#eF"lan+SlP during both normal and emergency eperatiensqeldilia6.

b. Technical Support Center (TSC)

TSC staff will assess pla#fagiliqlconditions, and provide management and technical assistance to the Control Room, as required, to mitigate the effects of the emergency event. The TSC staff will analyze and track parameters relating to the technical EALs, and will advise the Emergency Director of the need to reclassi8r the emergency. ln 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.

5-9 DBNPS Post-Shutdown Emergency Plan Revision 33IBD 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. The primary function of the Onsite and Near Site Emergency Response Organization is to relieve the Control Room staff of those dutiesandresponsibilitiesnotdirectlyrelatedtothe@

     @safe                          storage of spent fuel in the SFP.

5.4.3 Control Room In the Control Room, the Onsite Emergency Response Organization is the same as the Onshift Emergency Response Organization. @ thSG+4anager 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 these facilities are directed by the Emergency Plant Manager. The following individuals report directly to the Emergency Plant Manager:

a. Emergency Assistant Plant Manager The Emergeney Assistant Plant Manager is tlre senier eem^an)'

The Emergency Assistant Plant Manager is responsible for coordination and interface between the TSC emergency organization and the plan+fasili$. The Emergency Assistant Plant Manager advises the Emergency Plant Manager on planffacrili[ status and trends, and their potential impact on protective action recommendations and emergency classification. The Emergency Assistant Plant Manager interfaces with the Emergency Plant Manager, TSC Engineering Manager, Emergency Radiation Protection Manager, and the OSC Manager. Reporting to the Emergency Assistant Plant Manager is the Shift Manager and the Operations staff, in the Control Room.

5-10 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

b. Emergency Radiation Protection Manager The Emergency Radiation Protection Manager is located in the TSC and is responsible for ensuring radiological assessment and surveys are conducted within the Protected Area. The Emergency Radiation Protection Manager coordinates planffaqtltqlprotective action and health physics support for emergency activities, and interprets data to provide health physics and chemistry input to engineering assessments. The Emergency Radiation Protection Manager interfaces with the Dose Assessment Coordinator to provide data on planffaqilislradiological status and trends. In addition, the Emergency Radiation Protection Manager provides recommendations to the Emergency Plant Manager for emergency personnel doses, and the issuance ofPotassium Iodide to plan+

facilitv personnel. The Emergency Radiation Protection Manager interfaces with the TSC Engineering Manager, the Emergency Security Manager, the OSC Manager, the OSC RP Coordinator, the Dose Assessment Coordinator and staff.

c. Technical Support Center (TSC) Engineering Manager The TSC Engineering Manager is responsible for_perfol4ilg_al engineerinq assessment of Blantfacility conditions and/or actions needed to mitigate damage to the plantfacilitv. continuously evaluate the need for engineering resources. and the coordination and supervision ofTSC engineering activities associated with development of emergency procedures to terminate or mitigate the emergency situation. The TSC Engineering Manager 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 Manager advises the Emergency Plant Manager on information pertinent to emergency classification, from the technical standpoint.

The TSC Engineering Manager interfaces with the Emergency Assistant Plant Manager, OSC Manager and the Emergency Radiation Protection Manager. Other augmented. qualifi ed engineering resources that may be requested Rleportir+g to the TSC Engineering Manager

  @insl,ead.
  @iner&

5-l I DBNPS Post-Shutdown Emergency Plan Revision 33TBD The TSe Engineerint tead reperts te the TSe Engineering lr4anager and i ion Preteetien*4anager,

5-12 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Reperting te the TSe F ins+

    @ies L-------+lee+rieal 3--+Aeehanieal M

The TSe eperatiens [,ead is ^taffed as apprepriate; and is respensible fer enineerin gineering staff, The TSe eperatiens tead reperts te the TSe Engineering Manager; and i ion Preteetioa-Manager' ise-in varieus aspeets efplant eperatiens and ee"nputer teehnelegy-f.d. Emergency Security Manager The Emergency Security Manager 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 Manager reports to the Emergency Plant Manager and interfaces with the Emergency Radiation Protection Manager, and the OSC Manager. tr, The Emergeney Faeilities Serviees Manager reperts te the ergeney eperatiens Faeility is b}__---regkeepefs O-------e+eriea+ el--A4ainter+anee {@

5-13 DBNPS Post-Shutdown Emergency Plan Revision STBD

                      @ing-anmergenq+

ies.. e}--_-Phene-seroie,

                      @ion e) Suppert as requested by the TSe Engineering         Manager, ien systemsduringmrgeneies.,

he. 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 Manager The OSC Manager is responsible for the supervision of OSC personnel and 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:

l. Emergency Repair

2. Search and Rescue

5. First Aid

4. Fire Brigade The OSC Manager reports to and interfaces directly with the Emergency Plant Manager and interfaces with the Emergency Assistant Plant Manager and the Emergency Radiation Protection Manager. Rep+ting{o{heSe The OSC Radiation Protection Coordinator repofts to the OSC .

5-14 DBNPS Post-Shutdown Emergency Plan Revision 33TBD eb. The OSC Radiation Protection Coordinator The OSC Radiation Protection Coordinator dispatches RP-nd@ technicians within the protected area to survey, sample, and analyze various systems and/or areas to determine the emergency radiological conditions. The OSC Radiation Protection Coordinator also provides radiological support for emergency repair teams, the fire brigade, and first aid teams. The OSC Radiation Protection Coordinator reports to the OSC Manager, and informs and is advised by the Emergency RP Manager. Reporting to the OSC Radiation Protection Coordinator are all RP and ehrnisttftesters not specifically assigned other responsibilities within the emergency organization. dq. 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- l5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD fd. 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 a J First Aid 4 Fire Brigade Members of the OSC Personnel Pool report to the AssistanlOSC Manager @iners sEngineers will be eelleC eut te suppert

5-r6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 . However, the Emergency Response Manager 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 manr+i*g-Sl4lfi.qgto satisfu 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)

5-17 DBNPS Post-Shutdown Emergency Plan Revision 33TBD In the event that the station is not accessible, OSC personnel will muster at the Lindsey Emergency Response Facility and standby to support the p{ant fac i I ity mitigation strategy. 5.5.2 Emergency Operations Facility (EOF) Organization Under the direction of the Emergency Offsite Manager, the following positions staff the EOF.

     *-----+lRCtiaisen i"ing NRe tiaisen will be
     @isor ea.      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 tlrc,L{)F{)pemtirllrs Advisor anil the Emergency RP Manager. The following individuals report directly to the Dose Assessment Coordinator:

1. Dose Assessment Staff The Dose Assessment Staff is responsible for evaluating plan+

facilit-v and meteorological parameters associated with a potential or ongoing radiological release. 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 Assessment Staff interfaces with the RMT Coordinator and Rad Data Technician.

5- 18 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

2. Radiation Monitoring Team (RMT) Coordinator The RMT Coordinator is responsible for coordinating the activities of the RMTs 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 RMT Coordinator interfaces with the RTL Coordinator and the Dose Assessment Staff. Reporting to the RMT 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.

4. Radiation Monitoring Team (RMT)

Each Radiation Monitoring Team is comprised of two individuals who have been trained in radiological and environmental sampling techniques. The RMT members are responsible for taking air, water and soil samples, performing radiation surveys, and using associated survey equipment. db. 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.

5-19 DBNPS Post-Shutdown Emergency Plan Revision 33TBD The Emergency Planning Advisor

                   @                                  forthe procurement ofpersonnel and equipment.

Reperting te the Eme he EOF Communications Staf The EOF communications staffis 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 the Nuclear A member of the between the and the NRC. The EOF Communications staff may be augmented by additional personnel to assist in communications, Nuclear Network transmissions, and operations of support equipment. es. 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) The Emergency Public Information staff is activated by call tree notification, and operates the Joint Information Center (JIC). Coordination of the JIC is the responsibility of the JIC Manager, who reports to the Company Spokesperson. 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

s-20 DBNPS Post-Shutdown Emergency Plan Revision 33TBD operation of the CAC and ensures that CAC activities are carried out in a manner that supports the requests made by the Emergency Director.

5-21 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 5.8 SupportingEmergencyOrganizations 5.8.1 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. Sample letters of agreement are contained in Appendix C.

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

1. H. B. Magruder Hospital

2. Mercy St. Charles Hospital J. 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. 5.8.2 Medical EmergencyResponse Organization

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

l. 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 Responsibi lities

1. General Plant Manager:

5-22 DBNPS Post-Shutdown Emergency Plan Revision 33IBD The General Plant Manager is notified in all cases of serious personnel injury or illness. 2 First Aid Teams: 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) InjurieslnvolvingRadiologicalComplications: l) 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 patient's 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. RadiationProtectionPersonnel:

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 person's 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.

s-23 DBNPS Post-Shutdown Emergency Plan Revision 33TBD d) Shall provide the attending physicians with prompt evaluations ofthe internal and/or external doses incurred by injured personnel. The services ofthe radiological emergency assistance provider are available for assistance in this matter.

4. Davis-Besse Security:

Shall notifu 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. RadiologicalEmergencyAssistanceProvider:

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  :

5-24 DBNPS Post-Shutdown Emergency Plan Revision 3+TBD 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. If a dose falls outside the acceptable limits of 10 CFR 20.2202(a)(l), 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. 5.8.3 Government Agency Support 4.. Agreements with Government Agencies 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 pkn+faSt!ry, or a transportation accident, rests with the State of Ohio and local governments. Through the provisions of the Atomic Enerry 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 s) Ohio Emergency Management Agency (OEMA) h) Ohio Environmental Protection Agency 2 The Post-Shutdown Emergency Plans for DBNPS, and the emergency plans for the State of Ohio, Ottawa County and Lucas County, have been formulated to provide timely notification and close coordination with these agencies. J 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

5-25 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 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 Sheriffs Office or the Ottawa County Emergency Management Agency (OCEMA) d) Lucas County Sheriffs Office or the Lucas County Emergency Management Agency (LCEMA) e) Ohio Emergency Management Agency or Ohio Highway Patrol 0 NRC, Emergency Incident Response Center 2 In the event of personnel injury/illness, which require transportation to an offsite medical facility, the Ottawa County Sheriffls Office will be notified so that local authorities may prepare to answer public/media inquiries. J 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 Director will ensure that the Ottawa and Lucas County Sheriffs 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 notifuing the NRC. In the event that the ENS is unavailable, the NRC commercial number will be used. If

5-26 DBNPS Post-Shutdown Emergency Plan Revision 33TBD radiological concerns arise, the NRC Health Physics Network should be utilized. c Local Agencies

l. Ottawa County Sheriffs Office The Ottawa County Sheriffs Office is experienced in providing area control, communications assistance, and direct handling of the local population; including evacuation, should it become necessary. The Sheriffs Office provides 24-hour radio communication coverage with the Central Alarm Station at DBNPS. Until the OCEMA is activated, the Ottawa County Sheriffs Office is the lead Ottawa County agency contacted in the event of an emergency at DBNPS.

2. Lucas County Sheriffs Office The Lucas County Sheriffs 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 Sheriffs Office is the lead Lucas County agency contacted in the event of an emergency at the site.

  )        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 lettefs 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.

5-27 DBNPS Post-Shutdown Emergency Plan Revision 3318D c) Coordinate preparation ofannexes 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. 0 Develop notification methods and procedures, which will include communication with the nuclear facility licensee. s) Coordinate with adjacent states in matters pertaining to radiological emergency planning. 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. i) Make provisions for the alerting of boaters on Lake Erie inside the l0-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 mileEPZ 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.

5-28 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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.

4. Ohio Department of Health shall:

a) Coordinate Department of Health planning for radiation emergencies at licensed nuclear facilities. b) Provide guidance and supportto 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: l) Relocation of hospitalized persons.

2) Utilization of hospitals and other medical facilities during radiation incidents.

3) Assuringenvironmentalsanitation.

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: l) 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).

5-29 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

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. 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 Engineer's 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 Department of Energy (DOE), Chicago Operations Office, Radiological Assistance Program (RAP)

Upon notification of ahazard 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)

5-30 DBNPS Post- Shutdown Emergency Plan Revision 33TBD Region V, USEPA, Chicago, will provide support to the DOE, Chicago Operations Office, upon request. This support consistg 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 ofan 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 notifting boaters on Lake Erie. 5.8.4 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: l, O're ef the reles ef INDO is te assist the affeeted utility in qHiekly applyine r ta SITE r\RE,\ EMERGENCY and GBNER\I i@ f,filetions; ion onel+i ir ise 4, To suppeft these funetiens; INPO maintains the fellewing

                       @itis+

5-3 1 DBNPS Post-Shutdown Emergency Plan Revision 33TBD ffi ing b) Werk u'ith the INPO DuB Persen; in Atlanta; te iens'

                                                  ; in initiating and i

6, The president ef INPO rvill direet an analysis of ba. Davis-Besse'slnsuranceCarriers I 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 (AND will be notified in accordance with the Emergency Plan Implementing Procedures.

5-32 DBNPS Post-Shutdown Emergency Plan Revision 33TBD J In the event ofan 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 ofthe 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.

6. Nuclear Electric Insurance Limited is the Station's property damage carrier and is notified of situations requiring their attention by appropriate Station procedures.

eb. Nuelear Stearn Supply S) stem (NSSS) Vender and Architect/Engineer Support The NSSS vender for the Davis Besse plant r^ ^:r:t' was tlre known as Areva-NP The ArchitecV Engineer (A/E) for construction of the Davis-Besse planrfusiUqlwas the Bechtel Power Corporation. _@ can be called on during emergency situations to provide the technical analysis and engineering support necessary to miti gate abnormal pfar+faqtltOlconditions. dq. 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.

s-33 DBNPS Post-Shutdown Emergency Plan Revision 33IBD

5-34 DBNPS Post-Shutdown Emergency Plan Revision 33IBD TABLE 5-1 MANPOWE& LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Page I of2 A. ONSHIFT MINIMUM STAFFING REQUIREMENTS b0 E Functional Area Major Tasks Emergency Positions 0d g(t) E=

                                                                                                        !E
                                                                                                       <,    ut Shift Manager R9/ Cg4liflsl Fuel Handler (CFH)

I

1. Plant Operations and @ +

Assessment of Control Room Staff Shi+ninr{S$)

                                                                                                          +

Operational Aspects Reatrera+or za Non-tieense*Qg4i fi g{Operator 2+ (NCOXEO3))

2. Emergency Direction and Command and Control Shift Manager 1 (a)

Control (a) Licensee CAS Operator

3. Notification &

1 Local/ State NL+NCO or above I (a) Communication Federal N++NCO or above 1 (a) Dose Assessment @ 1 (a) above

4. Radiological Assessment In-plant Swveys RP Technician I (a)

Onsite Surveys RP Technician 1 Chemistry ehe*nisgrRP Technician lG)

                                                                  @                                        (a)

Technical Support - OPs above 1

5. Plant System -eereDatnage @ +@

Engineering, Repair, and eb+e Mitigative Actions Mechanical Repair I (a) Repair and Mitigative Actions Electrical Repair I (a) I&C Repair I (a)

6. In-Plant PAs Radiation Protection RP Technician 21(a)

Fire Brigade Captain lG)

7. Fire Fighting (RoNeQe3) 4 Fire Brisade Member

8. 1't Aid and Rescue N{,ENCO 1 (a)

Security Shift Supervisor I

9. Site Access Control and Security & Accountability CAS Operator 1 Accountability Securiry Personnel o)

TOTAL: rs10 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 Post-Shutdown On-Shift

5-35 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 5-I MANPOWE& LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Staffing Analysis Report, documents the minimum shift's ability to implement the emergency plan. Operations personnel anae*m;s+ry+een+ieian+are qualified on survey instruments. (a) May be filled by someone filling another position having functional qualifications. (b) Per DBNPS Physical Security Plan.

5-36 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 5-I MANPOWE& LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Page2 ofZ B. AUGMENTED EMERGENCY RESPONSE STAFFING REQUIREMENTS ALERT, SITE AREA EMERGENCY, UNUSUAL EVENT GENERAL EMERGENCY PERSONNEL TIME PERSONNEL TIME CONTROL ROOM CONTROL ROOM lEmergency Assistant Plant Manager (1)' Alerted Emergency Assistant Plant Manager (1 )3 Normal Hours: I 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 (2t) 30 minutes

                                                                              ,nstrumen{ & controls                                      (a Electrical Maintenance                                    (21)

Add Total Off Hours: RP Technician (1) (2) 60 minutes enemrstry+eenneAn (o) (r) RP Technician (31) (53) 't-2 hours ehePAtCf+eh+iias (1) (4 TecxurcRl supponr cexreR TECHNICAL SUPPORT CENTER As Required: TSC Engineering Manager (1) Alerted TSC Engineering Manager (1) Normal Hours:

                                                                              @                                                          (1)    30 minutes Off Hours:

60 minutes TSC l&C Engineer e) TSC Electrical Engineer (1) 'l-2 hours TSC Mechanical Engineer (9lel-i!-as necessarv 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: 60 minutes RMTS (3) 30-60 minutes Emergency Director (1) NRCtiaisen ('1) 1-2 hours State/County Communicator (1) NOTES: l. All time requirements are based on optimum response conditions.

2. Figure 5-2, Emergency Response Organization, depicts functional levels beyond these augmented staffing requirements.

                    ?   'I'La trnaar^An^., A""i"r--r   PI arrt M ,nroor rrre\/ rccnnnd ln lhc T(t-

5-37 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-1 ONSHIFT EMERGENCY ORGANIZATION Page 1 of 1 Shifl Manager Radiation Proteciion Certified Shift Maintenane Security Operator Personnel Shift Supervisor Operations Nuclear Personnel Security Force

5-38 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-I ONSHIFT EMERGENCY ORGANIZATION Page 1 of 1 Shift Manager Radiation Protection OperatiorE Security Personnel Shift Supervisor Nuclear Security Force

5-39 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 1 of 10 Emergency Director Emergenry Plant Emergency Offsite Company Spokesperson Manager Manager see figure S-2page2 see figure 5-2 page 8 see figure 5-2 page '10 Responsibilities: Responsibilities: Responsibilities:

-Plant Operations            -OfEite Communications   -Communications with the
-Engineering                 - Dose Assessment        News Media Assessment
-Radiation Protection
-Repair Activities
-Station Security

5-40 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 2 of 10 Emergency Plant Manager Recovery Advisor Emergency Assistant TSC Emergency 0sc Emergency Plant Manager Engineering Manager RP Manager Manager Seur,ty Manager see figure 5-2 page 3 see figure $2 page 4 see figure $2 page 5 see figure $2 page 6 see figure $2 page 7 ReEonsibilities: Responsibilities: RespnsJbilities: Respnsltilities: ReEonsibilities: - Plant 0perations - Engineeing Assessment - Radologcal Evaluation - Emeqency Repais - Access Contrd

                              - Core Damage Assesment       - ChemistryEvaluatim    - Search & Rescue       - $dion Seordty
                                                                                    - Damage Cmtrd

5-41 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergenry PlantManager Emergency lssistant TSC Emergency 0sc Emergency Plant Manager Engineering Manager RP Manager Manager Security Manager see figure $2 page 3 see figure S2 page 4 see figure 5-2 page 5 see figure S2 page 6 see figure 5-2 page 7 Responsibilities: ReEonsibilities: ReEonslbililies Responsibilities: ReEonsibililies: - Plant 0peratiom - Engineang Isessment - Radiological Evaluatim - Emeqency Repaim - Acces Contrd

                                                       - Chemistry Evaluation   - Search & Rescue      - Station $ority
                                                                                - Dana6 Cmtrd

5-42 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGT]RE 5-2 Emergency Response Organization Page 3 of 10 Emergency Assistant Plant Manager Control Room Commuricator Manager Shift Engineer (Shift Technical Advisor) 0perations Personrel Emergency Assistant Plant Manager ControlRoqn Communicator shift Manager 0perations Personnel

5-43 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 4 of 10 TSC Engineering Manager Lead Lead Cordlhrmd TSC TSC T$ TSC Operation TSC Compula SAll Hydradic Erginer l\lefranicd Eldrid t&c Engineas Tmhnicia Engineer Engineer Enginer Engireer (4) TSC Engineering Manager

• eptienal positien that ma,'be staffed at the diseretion ef the TSe Bngineering Manager,

5-44 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 5 of 10 Emergency RP Manager OSC RP Coordinator RP Chemistry Technicans Technicars

5-45 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 6 of 10 OSC Manager OSC System Emginers OSC RP Assistant Coordinator OSC Manager RP &Chemistry RP Briefe/ OSC Pd OSCTearn 0peratiors Personnel Debriefs Personnel Briefs/dehiefs Personnel 0sc Manager OSC RP OSC Pod Personnel Coordinator RP &Chemistry Personnel

5-46 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 7 of 10 Emergency Security Manager Scurity 0cA Shift Supervisu Security Supervisor Nuclea Security Force

5-47 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 8 of 10 Emergency Offsite Manager EOF 0perations Advisor Dose Assessment Emergency Emergency NRC Tecfnicd Liaison - Coordinator Facili$ Services EOF Planning Liaison Commrnicata Manager Advisor see figure S2 p4e 9 fusembly Aea Log & State of 0hio Coorclnata Status Boad Keepers (EOF) Tectnicd Liaison - Maintenarre Services State/ Counly Ottam Conty Personnel Commmicato Resoure Teclnicd Liaison Cmrdnata Lucas County Warehouse Pod Personnel

s-48 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Offsite Manager Dose Assessment Emergency Technical Liaison - EOF Coordinator Planning Communicata Advisor Technical Liaison - see flgure 5-2 page 9 State / County State of Ohio Communicaton Technical Liaison - Ottaua County Technical Liaison - Lucas County

5-49 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Emergency Response Organization Page 9 of 10 hse,Assessment Coordinator Coordinator Coordinator ,{ssessors (4 DBAB Field RMTs R[rlTs

5-50 DBNPS Post-Shutdown Emergency Plan Revision 33IBD FIGURE 5-2 Dose Assessment fuordinator RTL RMT Dose Assessors Coordinator Coordinator (1) DBAB Field RMTs RMTs

5-51 DBNPS Post-Shutdown Emergency Plan Revision STBD FIGURE 5-2 Emergency Response Organization Page 10 of 10 Company Spokesperson Jrc Public Affairs Manager Duty Officer Security Jtc News Sbtement Write Coordinator irc PR Commtnicator Communicator Audio/Visual Technical Coordinata Briefer Public lrquiry Media Hotine 0peata Assistant (1) (2)

5-52 DBNPS Post-Shutdown Emergency Plan Revision 33TBD FIGURE 5-2 Company Spokesperson Jrc Manager Security Technical PuUic lrquiry Briefer Hotine Opaator (1) Media Assistant (2)

6-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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-l 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 Emergenclu 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 Director, will implement this plan by initially classiffing 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. o 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 l5 minutes. Any subsequent changes to PARs continue to be provided to the agencies within 15 minutes. o Nuclear Regulatory Commission (NRC) The NRC is notified immediately after notification of the appropriate state and local agencies and not later than one ( I ) hour after the time of initial event declaration, escalation to a higher classification level, emergency termination or entry into recovery.

6-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 commercial telephone service. An open, continuous communication line is maintained with the NRC Operations Center upon request. An NRC Event Notification Worksheet (Form 361) may be utilized to assist in communicating event and p#faqili_qlinformation 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. a Support Organizations Medical, rescue, and firefighting support services are notified for assistance as the situation dictates. The Institute ef Nuelea* Pen'er eperatiens (lNPe) is netified at an Alert er higher

    -     The American Nuclear lnsurers (AND 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 verifiz that the most appropriate classification is made. Depending on the level of the emergency and its severiqz, 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 gen+e++eer+Nq:

Ceftified Operator(s) and/or the Shift Manager will be made aware of the situation by alarms, instrument readings, reports, etc. The en+rel-ReemNon-Certifi ed 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., planlsystems and reaeto+-ee+e$!! status, radiological conditions, etc.) in the following manner:

I Determine the immediate actions to be taken @ Preeedures and theEl o ensure the safe and proper operation of the plar*SIP. Teelrnieal Adviser (STI\I will advise and assistthe SIrift Manager en rnatters

6-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD eemair+ir+g{eth safety and preper ith regards te nue@.

2. If the situation requires implementation of the DBNPS Post-Shutdown Emergency Plan, the Emergency Director will:

a) Classifu the emergency. Classification of emergencies is a non-delegable responsibility of the Emergency Director. 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) Notifr the following personnel and organizations of the emergency conditions: r) Nuclear Security Supervision.

2) Station Management.

3) Ottawa County Sheriff/EMA (within 15 minutes).

4) Lucas County Sheriff/EMA (within l5 minutes).

s) Ohio State Highway Patrol/EMA (within l5 minutes).

6) Key Emergency Response Personnel.

7) NRC, Emergency Operations Center, Bethesda, Maryland (within one hour).

0 Provide periodic follow-up notifications. s) Recommend protective actions for public protection, as needed. Recommending public protective actions is a non-delegable responsibility of the Emergency Director. a J 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 plan+SFP. 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 Post-Shutdown Emergency Plan Revision 33TBD 6.1.2 EmergencyDirector The designated Emergency Director, upon being informed that an emergency exists and has been declared by the Emergency Director on-shift will:

a. Review information, data, and methods used by the on-shift Emergency Director (Shift Manager) in making the emergency classification. The Emergency Director may NOT delegate the responsibility of classiffing emergencies.

b Determine, to what extent the Emergency Response Organization (ERO) will be activated, using the following guidelines: For an TINUSUAL EVENT, key individuals in the ERO will be alerted or mobilized at the discretion of the Emergency Director. 2 For an ALERT, all of the ERO will be activated. Key individuals in the CAC will be alerted. J 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.

e. Ensure 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.

f. Ensure 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 notifu 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 willnotiflz 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 Post-Shutdown Emergency Plan Revision 33TBD 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 hours 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 hours. 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 Post-Shutdown Emergency Plan Revision 33TBD 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 LINUSUAL 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 ptan+fac:iliqlinstrumentation 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-plan#acriliblinstrumentation.

b. If possible, the dispatching of shift personnel to the identified problem area to confirm and visually assess the problem.

c. The dispatching of personnel to monitor for possible releases, and to confirm the correct classifi cation.

d. If a radiological incident is occurring, surveillance of the in+fa#fuiliry 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 Director. Emergency Plan Procedures are provided to allow a rapid, consistent projection ofdose.

e. If a security event is in progress, then the emergency organization will immediately implement specific procedures for security events or threats.

6-7 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 eere-$Fl status,-e6;i )

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 RMTs 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 Post-Shutdown Emergency Plan Revision 33TBD 6.3 Mitigative Actions Detailed operating procedures are available for use during emergencies, as well as during normal operations. Specific Fme+geneyperatir+g-Preeedures and Abnermal Pprocedures are provided to assist the operators in placing the plant-faqiliqlin a safe condition, and taking necessary supplemental mitigative actions. In addition, opetatitxt; personnel are trained in the operation of the p{anlSIP 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 Director 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 Director. 6.4 Protective Actions Protective actions are emergency measures taken during or after an emergency situation to minimize or eliminate thehazard 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 Pla#EAqjliqlSite 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. pknrEaqili5lS ite (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 assembly areas. Personnel will be trained as to the location of assembly areas and the suggested routes to each. Visitors will assemble with their escorts, or be escorted offsite. At the assembly areas, members of the emergency organization will conduct personnel assembly and evacuation (if required).

6-9 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Accountability within the protected area is coordinated by the OSC Manager and Security. The goal for completion of personnel accountability is 30 minutes. Results are forwarded to the Emergency Director. 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.8., 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 il at the discretion of the Emergency Director/Shift Manager, a personnelhazard exists. Nonessential personnel shall be evacuated from the site if a GENERAL EMERGENCY has been declared, or if at the discretion of the Emergency Director/Shift Manager, site evacuation is warranted for personnel safety reasons. Access control will be established by Security to prohibit the entry ofunauthorized personnel to the protected area. Personal vehicles will be used for site evacuation. Nonessential personnel may be evacuated to the designated offsite assembly area; the Lindsey Service Center, or other company facilities as appropriate. Personnel and vehicles will be monitored for contamination at the offsite assembly area, if necessary, prior to release.

b. PlanlE4giliqlSite (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 as described below. At other site locations (i.e., Davis-Besse Training Center, Davis-Besse Administration Building and Annex, Warehouse), 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:

o Site evacuation via normal exits

6-10 DBNPS Post-Shutdown Emergency Plan Revision 33TBD o Site evacuation via alternate means o Dispersal of personnel. and essential ERO members o Take Cover (sheltering in place for personnel onsite) 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 tle The Ohio Radiologi 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 l, and its PAR logic diagram. The process includes consideration ofprecautionary 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 l0-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 PlanningZone, 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 Sheriffs 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.

6-1 I DBNPS Post-Shutdown Emergency Plan Revision 33TBD 6.4.3 Use of Onsite Protective Equipment and Supplies Table 6-l 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 Laboratory 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 EmergencyPersonnel 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-92-001guidance for these emergency activities:

6-12 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

a. Miti gative/protective actions :

Limit doses to the following when protecting valuable propertv and lower doses are not practicable: I 10,000 mrem Total Effective Dose Equivalent (TEDE) 2 30,000 mrem Lens Dose Equivalent (LDE) 5 100,000 mrem: a Total Organ Dose Equivalent (TODE) a 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: I 25,000 mrem TEDE 2 75,000 mrem LDE J 250,000 mrem a Total Organ Dose Equivalent (TODE) a Shallow Dose Equivalent (SDE) to the skin of the whole body or to any extremity The Emergency Director 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 ofsuch 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 Director 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 Director or, when designated, the Emergency Plant Manager shall authorize the use of the thyroid blocking agent, i.e., potassium iodide (KI).

6-13 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 Post-Shutdown Emergency Plan Revision 33TBD 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 Post-Shutdown Emergency Plan Revision 33TBD TABLE 6-1 PAGs for the Early Phase of a Nuclear Incident PAG Protective Action (Proiected Dose) Comments Evacuation (or shelteringr) l-5 rem2 Evacuation (or for some situations, shelteringt) should normally be initiated at I rem. Administration of stable iodine 25 rem3 Requires approval of State medical officials 'Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration offactors 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 sigrrificant 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 Limit' Activity Condition (rem) 5 all l0 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

'Sum 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 exhemities) 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 Post-Shutdown Emergency Plan Revision 34TBD TABLE 6-2 RECOMMENDED PROTECTIVE ACTIONS Accident Phase Exposure Pathway Examples Of Actions To Be Recommended Emergency Phaser lnhalation of gases, radio- Evacuation, shelter, access control, (0 to 4 hours) iodine, or particulate respiratory protection, prophylaxis (thvroid 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 TNTERMEDIATE Ingestion of fruits and Wash all produce, or impound produce, PHASEz vegetables delay harvest until approved, substitute uncontaminated produce Ingestion of water Cut off contaminated supplies, substitute from other sources, filter, demineralize (4 to 48 hours) 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. 'Emergency phase - Time period of major release and subsequent plume exposure. 2lntermediate phase - Time period of moderate continuous release with plume exposure and contamination of environment. 3long Term Phase - Recovery period.

6-17 DBNPS Post-Shutdown Emergency Plan Revision STBD TABLE 6-3 REPRESENTATTVf, SHIELDING FACTORS FROM GAMMA CLOUD SOTIRCE Shielding' 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 0.7: Masonry House (no basement) 0.6 0.4 to 0.73 Basement of masonry house 0.4 0.1 to 0.5: Large office or industrial 0.2 0.1 to 0.3ea building 'The ratio of the dose received inside the structure to the dose that would be received outside the structure. 2,{ wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes. 3This range is mainly due to different wall materials and different geometries. +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 Post-Shutdown Emergency Plan Revision 33TBD TABLE 6.4 SELECTED SHIELDING FACTORS T'OR AIRBORNE RADIOI\IUCLIDES 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 Post-Shutdown Emergency Plan Revision 33TBD TABLE 6-5 REPRESENTATTVE SHIELDING FACTORS FOR ST]RFACE DEPOSITED RADIOI\IUCLIDES Structure or Location Representative' Representative Shieldine Factor Range 1 m above an infinite smooth surface 1.00 1 m above ordinary ground 0.70 0.47-0.85 I m above center of 50-ft roadways, 0.55 0.4-0.6 50oZ 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.s Trains 0.40 0.3-0.5 One and two-story wood-frame house 0.42 0.2-0.s (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 0.05, 0.03-0.07 exposed Two stories, less than 2 ft of basement, walls exposed 0.03, 0.02-0.05 Three- or four-story structures, 5000 to 10,000 ff3 per floor First and second floors 0.0s, 0.01-0.08 Basement 0.01, 0.001-0.07 Multistory structures, >10,000 sq. ft. per floor: Upper floors Basement 0.01, 0.001-0.02 0.00s, 0.001-0.015 'The 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 l97S).

6-20 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 6-6 Page I of2 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-131' Cs-1342 Cs-1372 Sr-90 Sr-89 Initial Activity Area Deposition (pCi/m2) 0.r3 2.0 3.0 0.5 8.0 Forage Concentration3 (pCi/kg) 0.0s 0.8 1.3 0.18 3.0 Peak Milk Activiry (rrCi/l) 0.015 0.15 0.24 0.009 0.14 Total Intake (pCi) 0.09 4.0 7.0 0.2 2.6 'The cumulative intake of lodine-I33 via milk is about 2 percent of lodine-131 assuming equivalent deposition. 2lntake of Cesium via the meaVperson 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 oftwo. 3Fresh weight. Reference Federal Radiation Council. Radiation Protection Guidance for Federal Agencies. Federal Register (May 22, 1 965).

6-21 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 6-6 Page2 of2 GUIDELINES F'OR 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-13 I Cs-134'? Cs-137 Sr-90 Sr-89 Infant3/Adult Infant4/Adult Infant4/Adult Infant4/Adult InfanC/edult Initial Activity 1.3/r 8 20/40 30/s0 5.0120 80/1600 Area Deposition @Cilm2) Forage 0.5/7.0 8.0117 t3/19 1.8/8.0 301700 Concentration5 (pCi/kg) Peak Milk 0.01512.0 l .s/3.0 2.414.0 0.0910.4 1.4/30 Activity (pci/l) Total Intake 0.9110 40170 70180 2.017.0 261400 (pci) tThe cumulative intake of Iodine-l33 via milk is about 2 percent of Iodine-l3l assuming equivalent deposition. 'zIntake 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 of2. 3Newborn infant, includes fetus (pregnant woman) as critical segment of population for Iodine-l31 a"Infant" refers to child less than I year ofage. sFresh weight.

Reference:

Federal Radiation Council. Radiation Protection Guidance for Federal Agencies. Federal Register (May 22,1965).

6-22 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure 6-1 Page I of4 SUM MARY OF TYPICAL EMERGEN CY M EASURES ERO OFFSITE ACTIONS ACTIONS EVENT Prompty inform authorilies and en or Emergency Response Organization of the medical assistance, als ested Assess and re as needed. Augment personnel as needed erm summary to offsile authorities, or escalate to a higher classification if conditions warrant. until termi

6-23 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure 6-1 Page2 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 medicalassista AS uested ALERT Activate EOCs and other response Assess and d centers as needed. Activate O TSC EOF & JIC Alert key emergency personnel to status. Place RMTs on stand Alert Radiation Monito Teams Activate communication networks Maintain ALERT status until the CAC termination, downgrade, or escalation of the eme classification Provide period ic plenlfacilillstatus Provide meteorological conditions to offsite authorities. Make Senior Management and Technical personnel available to the County, State, and NRC for consultation. Assemble Protected Area rsonnel Terminate with verbal summary to offsite authorities, or escalate to a higher classification if conditions warrant.

6-24 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure 6-1 Page 3 of4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACTIONS SITE AREA ACTIONS EII/IERGENCY Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medicalassistan as SITE AREA EMERGENCY Activate sirens and transmit an Assess and EAS e Activate OSC, TSC, EOF, JIC Activate the State & County EOCs, and CAC. and other se centers. Dis RMTs. Alert personnel needed for evacuation of the blic to stand status. Activate communication networks. Dispatch key personnel and RMTs Make Senior Management and to locations. Technical personnel available to the County, State, and NRC for Activate communication networks consultation. Continuously assess data from D-B P rovide period ic plan+faqlXglstatus ates 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 classification. conditions cha

6-25 DBNPS Post-Shutdown Emergency Plan Revision 33TED 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 EAS message. Activate OSC, TSC, EOF, JIC Activate the State & County EOCs, and CAC. and other response centers. Dispatch RMTs Recommend sheltering or evacuating within a 2 mile radius of the plan{aqiljly, 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 personneland RMTs. County, State, and NRC for consultation. Recommend placing milk animals within 2 miles on stored feed and Provide 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 classifi cation as conditions change.

6-26 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure 6-2 Page I of2 EMERGENCY NOTI FICATION: UNUSUAL EVENT Davis-Besse Ottawa Lucas State of DBNPS Emergency Corporate ization US

6-27 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Figure 6-2 Page2 of2 EMERGENCY NOTTFICATION : 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

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7-l DBNPS Post-Shutdown Emergency Plan Revision 33IBD 7.0 EMERGENCY FACILITIES AND EOUIPMENT This section describes the equipment and facilities used at DBNPS to: Assess the extent ofaccident hazards. Mitigate the consequences of an accident. Provide protection to station personnel. Support accident mitigation operations. Provide immediate care for injured personnel. A diagram identiffing 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 facilitiesandmuchoftheequipmentisnormallyusedforroutine@.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 monitored. It contains the instrumentation, controls, and displays for:

4L. Electrical systems 52_. Safeff-sSystems SFP

61. Accident monitoring systems.

The epe+a+ing-on-shift is-.staffed_lg in accordance with TS 5.2.2-ar#-TRM-f02=f

                                  . Control manipulations and the safe operation of the p{an+SFP are directed by the                                     Shift Manager (qualified as a Cerlified Fuel Handler (CFH)) and-{J+i+Supenriser, and are performed by Non-
                   +Eieensedeg{jflpd Reae+erOperators.

b. During abnormal eperati*g-conditions, the complexity of Station responsibilities increases signifientlfand the Control Room transforms into an emergency response center. These responsibilities include the following:

1. Diagnosing the abnormal conditions.

2. Performing mitigative actions.

J. Mitigation of abnormal conditions.

4. Management of p-lanlS F P 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 pln+t-SFL to a safe condition.

7-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

9. Recovering from the abnormal conditions.

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 may 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 i+plantfacriliry 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. 7.2 Davis-BesseAdministrationBuilding(DBAB)Facilities The DBAB contains the Emergency Response Facilities (ERFs) necessary to assist Control Room personnel in accident assessment and abnormal eperati+g-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: L Help the Control Room staff determine the planffaqjliblsafety status.

2. Relieve the Control Room staff of peripheral duties and communications not directly related to reaeterSll system manipulations.

3. Prevent congestion in the Control Room.

4. Provide assistance Mepra{or}from technical personnel who have comprehensive plan+fac:iliql 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 planfaqilq1data to the NRC for its analysis of abnennafplar+

opera+ifl-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 Post-Shutdown Emergency Plan Revision STBD The unrestricted area consists of the Energy Education Center (EEC), a Site Emergency Operations Center (SEOC) and several worVconference 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 unintemrptible 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 seryes 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 planfacri.lig1transients 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 contained in the Emergency Plan Procedures 7.2.2 Radiological Testing Laboratory GTL) 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 Post-Shutdown Emergency Plan Revision 33IBD The RTL is on the ground floor of the DBAB 7 .2.3. 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 7.2.4 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 Post-Shutdown Emergency Plan Revision 33TBD 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 A4ddress systems. The facility is equipped with an unintemrptable power system and an emergency diesel generator. The Near Site Emergency rResponse 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 staffevaluates the magnitude and effects ofactual 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). The EOF utilizes various communication systems to establish and maintain communications with State, Federal, and local officials, and mobile Radiation Monitoring Teams (RMTs). The EOF provides space for at least 22 people. Activation and operation of the EOF is 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 operation 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 p{anrfaci-ljllstatus and emergency response actions. JIC facilities include news briefing areas for electronic and print media representatives. JIC support is available for any plan+faciljblemergency. However, facility activation is mandatory at (and above) the

7-6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Alert emergency classification level. The JIC is located at a FirstEnergy Corporation facility outside the lO-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/plan+faqiliry. 7.5 Countv 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 l0-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 Sheriff s 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 l0-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, 2144Monroe Street, Toledo, Ohio. Communications during an emergency at Davis-Besse are coordinated through this facility, and the Lucas County Sheriff s 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 Post-Shutdown Emergency Plan Revision 33TBD 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 A Private Branch Exchange (PBX) is used by the station for telephone communications. The PBX system provides six inlout bound offsite communications paths.

o 2 paths connect to the FirstEnergy company communications system. o 3 priority circuits travel to Toledo where then connect to the commercial telephone system.

                      . I priority circuit connects directly into the local 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 from the Akron Ohio West Akron Campus 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 p{an+fagilq1channels, 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 Sheriffs dispatcher.

3. A channel used exclusively by Security.

7-8 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

4. A channel used by the Maintenance Department for normal day-to-day transmissions.

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 megahera 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.

(}

b. A Computerized Automated Notification System (CANS) is available to facilitate the notification process. The system is composed of a minimum of 26 phone lines.

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 EmergencyCommunications Systems

a. The following phone systems are dedicated for emergency communications:

I The Davis-Besse 4-Way Phone including the State and County EOCs, the Ohio Highway Patrol Office, the Lucas County and Ottawa County Sheriffs dispatcher offices, the Emergency Operations Facility, and the Control Room.

2. A diverse network of commercial telephones, on unintemrptable power has been installed to provide:

a. NRC Emergency Notification System (ENS) telephone ("red phone").

b. NRC Health Physics Network GPN) telephones.

S) 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

7-9 DBNPS Post-Shutdown Emergency Plan Revision 33TED

2. Radiation Management Bridge 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 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 Emergency Response Manager. 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, IMTIATE EMERGENCY PROCEDURES, and ACCESS EVACUATION alarms sound in aU planlfacilillareas (i.e., station office building, personnel shop facility, radiologically controlled area, fuel handling area, outdoor areas, primary access facility, etc.)

7-10 DBNPS Post-Shutdown Emergency Plan Revision STBD 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 l0-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-I, REV. l. Local authorities activate the warning sirens from the Ottawa County Sheriffs 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 Sheriff s Dispatch Center as follows: o d three-minute audible test is performed at least once per year o d one-minute audible test is performed at least monthly o 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 Sheriffs 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 Sheriffls Offices have central dispatches, manned 24 hours 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 Post-Shutdown Emergency Plan Revision 33TBD 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 plan+faqiliry. 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 plan+faqiliglcan 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 AssessmentFacilities 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 pta*faqiliry, 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 Conhol 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 l2.l-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. T-he{a@adiationmonitorsarepoweredfromtheessentialinstrument distribution panels. The non-essential radiation monitors are powered from the unintemrptible instrument distribution panels.

d. ach 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.

7-12 DBNPS Post-Shutdown Emergency Plan Revision 33TBD f The modules are designed so that an alarm and/or indication is initiated when failure occurs anywhere in the channel. 7.9.2 Area Radiation Monitoring The Area Radiation Monitoring subsystem is comprised of area monitors located throughout the pla*faqiliry. Under normal operating conditions, the area monitors warn personnel of increasing radiation level, which may result in a radiation health hazard.

     @reamonitorsconsistingoftwotypes,Geiger-Muellerdetectors 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 ofthese channels is separate from the detector and is also housed in a weatherproof container.

the pest aeeident atmesphere in the eentainment, The deteeters are de-ensitized by a lead sHl+ The Control Room readout modules are located in the radiation monitoring panel in the Control Room. 7.9.3 Atmospheric RadiationMonitoring 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 RadiationMonitoring 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 Post-Shutdown Emergency Plan Revision 33TBD 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 (l) 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 plan#agillqland 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 I 0,000 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 ofthe 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 l% inch hose, with an adjustable fognozzle, and a separate 2%-inch hose connection for local fire department use. Fire extinguishers are provided throughout the building.

7-14 DBNPS Post-Shutdown Emergency Plan Revision 33IBD Hose reel units are provided in the turbine building. Each reel is provided with 50-75 feet of l% inch fire hose, and an adjustable fog and stream hose nozzle. Adjacent to each hose reel is a separate Z%-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.

l. 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

7-t5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 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 0.0109 (g=acceleration due to gravity). The recording system includes pre-event (i.e., pre-trigger) data in the event record. Recording continues without intemrption 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 In keeping with the purposes of the system, loss of site power will not prevent system operation.Backuppowerissuppliedfrom@aninternalbattery 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 MeasurementPrograms 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 atthe250 and 340-foot levels on the freestanding tower and at 35 feet on the satellite tower. Differential temperature measurements (AT) 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 datathrough the Data Acquisition and Display System (DADS). All meteorological data are recorded on strip chart recorders. Dual-channel strip chart recorders are used for recording wind speed and direction; one recorder for each

7-16 DBNPS Post-Shutdown Emergency Plan Revision 33IBD 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 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 planrSll systems-and{he+eae+or-i+self. aeei t eperaters, ant te a USAR Table 7.5-l provides a listing and a description of Control Room instrumentation; irf{#ing+AMs that would be used in performing continued assessment of p+an+faq[iry 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 planrSll operations. This equipment can also be utilized in the analysis of abnormal events tessis+irr+he-diagnsis o@io*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 GTL) 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.

Sampling Systern (PASS) *hieh rr'as designed speeifieally fer this purpese,

7-17 DBNPS Post-Shutdown Emergency Plan Revision STBD e, Fer eentainment afirosphere sampling; the rermal sampling proeedure is used, If ent samph Sample{ystem= db. 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 quanti$r radioactive particulate and iodine sampling media. Also if RE 4598 series Channel l, 2 or 3 is off scale, a portable survey instrument on the sample line can be used and dose rate is then converted to pCilcc. 7.9.11 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 has 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. Radiation Monitoring Teams (RMTs), dispatched at an ALERT or higher, will conduct emergency field monitoring of radiation and airborne activity levels throughout theEPZ, under direction from the Dose Assessment Center, in the EOF. Monitoring results will be used to verifu 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 Post-Shutdown Emergency Plan and are therefore discussed separately. A fundamental concept in personnel protection is the immediate release and removal of all individuals not essentialto the operation, safety, security, and damage control of the p+an+faqiIry. 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

7-18 DBNPS Post-Shutdown Emergency Plan Revision 33TBD with appropriate alarms and interlocks. Provisions have also been made for the air to be recirculated through high effrciency particulate ([IEPA), 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-purifring respirators are available in the Radiologically 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 p+a*faqilily. 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 permanently shutd 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 Post-Shutdown Emergency Plan Revision 33TBD TABLE 7.1 Page 1 of2 Radiation Monitorins Instruments and Equinment A Portable Radiation Survey Instruments Type Range Detector Quantity Location High Range 0-1000 5 RTL Survey mrad/hr-l03 radlhr GM a J RP Area Instruments Ion 0-50 R/hr Chamber 6 RTL Low Range Ion Survey 0-5 remlhr Chamber 2 RP Area Instrument 0-5 x 105 cpm GM 4 RTL Alpha Survey Meter 0-5 x 105 cpm Scintillator 1 RP Area Neutron 0-5000 mrem/hr BFs 2 RP Area B. Portable Air Sampling Equipment Type Quantity Location Environmental Offsite Air Sample 10 Survey Stations Low 12 volt D.C. 4 RTL Volume Battery Power 4 RTL High Volume I RP Area Onsite Low Volume 2 RP Area

7-20 DBNPS Post-Shutdown Emergency Plan Revision 33TBD TABLE 7-1 Page2 of 2 Radiation Monitorins Instruments and Equipment (Continued) C. Personnel Dosimetry and Equipment Range Self-Readin g 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 GLD) Radiation Monitor 0-50 kcpm (Frisker) Automatic Whole Body N/A Contamination Monitors

7-21 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Fieure 7-L EMERGENCY FACILITMS BY GENERAL LOCATION SUPPORT AGENCIES COMPANY (OFFSITE / GENERAL AREA) (oFFSTTE) (oNSrTE) State of Ohio Joint Control Room Emergency Operations lnformation Center (CTRM) Center (EOC) (Jrc) Davis-Besse Ohio Emergency 623'Elevation Management Agency Toledo Edison Plaza 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 FirstEnergy Corp. Third Floor Port Clinton, Ohio Toledo, Ohio Facility Technical Emergency Center osc) Nuclear Regulatory lnstituteof Nuclear Operating Facility Radiological Testing Commission (NRC) Power Operations (EOF) Laboratory (RTL) Operations Center Ernergeney Response Davis-Besse Response Facility Center (ERC) Lindsey, Ohio Administration Building Rockville, Maryland Atlanta-Georqra First Floor lncident Response Federal Emergency Site Emergency Center (lRC) Operations Center Operations Center NRC Region lll DOE, COO (sEoc) Lisle, lllinois Argon, lllinois Davis-Besse Administration Building Areva, NP Bechtel Power First Floor (Center) Corporation Lynchburq, Virqin Maryland

8-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 Yiee has been assigned the overall responsibility for emergency preparedness as related to the DBNPS. This responsibility includes not only maintenance of the DBNPS Post-Shutdown 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 V+e+resiaent _

   @isalsoresponsiblefortrainingofpersonnelwhoimplementthe Plan and Procedures. To assist the                                                                       in meeting these assigned responsibilities, an Emergency Response Manager, has been designated.

The specific responsibilities of the Emergency Response Manager are described in the following subsections; and in particular, subsection 8.1.3. 8.1 OrganizationalPreparedness 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 Manager. This training program provides for the indoctrination of Company employees andcontractors.Inadditionitprovidesspecializedtrainingfor@, chemistry personnel, radiation protection personnel, and personnel assigned specific responsibilities in the ERO. The is responsible for ensuring that personnel in each department receive the appropriate training. The Nuclear Group Department Directors are responsible for identifuing training required for each individual's job specialty. Training in support of the Post-Shutdown Emergency Plan, includes the following:

a. All DBNPS staff personnel requiring unescorted access will receive wil-l-+eei+e industry standard training for unescofted access to a nuclear power plant and an-v ific traini detennined DBN Reseons.

With regard to Ernerger"e,' Respense, the fellorving ehieetives have been established: l, State the purpese ef the D -^* el"tr -" - Emergeney Plan; and a-seeiated ies., 3, Reeogni-e the ernergene) alarms and ^tate the preper response fo- eaeh, 1, State tlre aetiens required during D-^' eL"*{^"'- Emergene}'Plan implementatien, 6, Identif)' the leeatien ef enrergene,' faeilities and assembl)' areas inside the 7, Diseuss evaeuatien plans; ineluding identifieatien sf ev.leuatien reutes,

8-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD news#dia-regarding-anmrgenet, 9, State the funetion 10, Identi8,the a^prepriate eemmunieetien system te be Hsed for reperting diseussiens, ien Restrie*d-a+eas'

b. Personnel assigned to the DBNPS ERO with specific Post-Shutdown Emergency Plan duties and responsibilities will receive specialized training for their respective assignments. Table 8-l 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 ofthe above-mentioned plans and procedures with the DBNPS Post-Shutdown 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 indochination and training. J 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 Post-Shutdowrr 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

8-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 Post-Shutdown 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/plan+fac:[igltour.

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:

Ensure that the participants are familiar with their duties and responsibilities. 2 Veriff the adequacy of the DBNPS Post-Shutdown Emergency Plan and Emergency Plan Procedures. J Test communications networks and systems. 4 Check the availability of emergency supplies and equipment. 5 Verif, the operability of emergency equipment. The Emergency Response Manager is responsible for the planning, scheduling, and coordination ofall emergency preparedness related drills and exercises. All drills and exercises are subject to the approval of the General Plant Manager. Exe+eise' Each drill requirement will be performed within the specified time interval, with a maximum allowable extension not to exceed25% 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 coachingmay 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.

8-4 DBNPS Post-Shutdown Emergency Plan Revision33TBD

b. When a major drill or exercise is to be conducted, the Emergency Response Manager will:

1. Assign personnel to prepare a scenario.

2. Coordinate efforts with other participating emergency personnel, or ganizations, and agenc ie s.

3. Obtain the approval of the General Plant Manager (DB)-and+hei+e Viee nresident DB Nuelear (for the Biennial Exereise).

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 Emergency Response Manager will noti$, 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 Post-Shutdown 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 Emergency Response Manager by observers or participants. The Emergency Response Manager 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 Emergency Response Manager.

8-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

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/inj ured 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 Post-Shutdown Emergency Plan Revision STBD 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, plafl#aqifiry 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) Radiation Monitoring Team (RMT) drills willbe 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 rvill be eendueted *hieh ineludes an analysis ef sitnulated elevated 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 Emergency Response Manager The Emergency Response Manager shall ensure that:

8-7 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

a. Information, data, and procedures detailed in the Emergency Plan Procedures are consistent with the DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan and Emergency Plan Procedures with the:

1 State Plans 2 County Plans J 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.

o D Periodic reviews and updates of the DBNPS Post-Shutdown 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 ofpreparatory 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 Wam ing Plans, Emergency Communications Development Plans and Countywide Resource Manuals.

8-8 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 8.2 Educational Information for the Public For those members of the public residing within the l0-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 ofthe 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 l0-mile Emergency Planning Zone. 8.3 Review and Update of the Post-Shutdown Emergency Plan and Emergency Plan Procedures DBNPS maintains, as separate documents; this Post-Shutdown 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 l, Final Safety Analysis Report (FSAR), will be maintained as a separate document. This is more clearly defined in the Updated Safety Analysis Report (USAR);Se*ie*133. 8.3.1 The DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan will be reviewed annually by an independent group with no immediate responsibility for the emergency response program. This group is the FENOC 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 Post-Shutdown Emergency Plan to verifii compliance at least once every two years. The CNRB performs this function by reviewing the audits which are performed by the FENOC Oversight organization. The report on the adequacy of the interfaces between the DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan at least annually to veriff compliance with the company's internal rules and procedures, federal regulations, and operating license provisions. Personnel

8-9 DBNPS Post-Shutdown Emergency Plan Revision 33TBD performing audits of the DBNPS Post-Shutdown Emergency Plan and/or Emergency Plan Procedures will take into account corporate policy, state policy and plans, county plans, and the various agreements and 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 Post-Shutdown Emergency Plan and Emergency Plan procedures will be reported to the . 8.3.3 The Emergency Response Manager will provide an ongoing review of the Post-Shutdown 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 Post-Shutdown Emergency Plan will be similarly controlled.

b. The Emergency Response Manager is responsible for coordinating the periodic review and audit of the DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan and amendments thereto, and the Emergency Plan Procedures and revisions thereto.

8.4 Maintenance and Inventory of Emergency Equipment and Supplies The Emergency Response Manager 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 Post-Shutdown Emergency Plan Revision 33TBD TABLE 8-1 Sheet I of 3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL PersonnelCategory InvolvedPersonnel Training and Frequency gmergenefA,ssis+an+

                     @                       Pmergeney Assistant Pfan+Managef          dsigna#-as Emergeny+ssistant Plan++4anager lieense*indi+iduals-tieet+sed             Shift Managers eperaterseqff,ed      UnitSupen*isers        @receiveextensiveon-Fuel Handlers         Other lieensed         the-job and formal training as scheduled and conducted Certified staff        by the @                               training program.

members This program shall-includeg a comprehensive review of the DBNPS Post-Shutdown Emergency Plan and the Emergency Plan Procedures. Personnel responsible Emergency Director, Training will include the Post-Shutdown Emergency for assessment of Emergency Plant Plan, Emergency Plan Procedures, Technical emergencies Manager, Emergency Specifications (that are referenced in the Emergency Offsite Manager, Shift Action Levels), and other station programs, plans, and Managers, Shi* procedures. The listed individuals attend at least one Teehnie*l r\dvisers meeting per year to receive training on the Post-(STAslKey Shutdown Emergency Plan and Emergenc), Plan Emergency Response Procedures. Detailed instructions with special attention Personnel given to the use of either dose assessment or engineering assessment techniques is provided based on the role they Staffpersonnel are expected to play during an emergency. Personnel designated by the shall participate in scheduled exercise and drills General Plant depending on availability. Manager who may act as OSC and TSC Managers ethen*en*bers-of+he FtulearGreutrsta#as desftna@ite Viee-Presiden+--DB Nt*el,ear' 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.

8-1 1 DBNPS Post-Shutdown Emergency Plan Revision 33IBD TABLE 8-1 Sheet 2 of3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL Personnel Catesorv Involved Personnel Trainins and Freouencv 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. PeslAee-ident ehm.istqrpersenne+ en an annual basis; detailed training shall be previded SanpUag+ersonne+ dsigna+ed#he e+m.istqrSuperYisor te-perfurm-P,+SS sampls 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 certiffing 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 ofthe 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 Post-Shutdown 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 Post-Shutdown Emergency Plan Revision 33TBD TABLE 8-1 Sheet 3 of3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL PersonnelCategory InvolvedPersonnel 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 offire 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 ofFleet 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 Post-Shutdown Emergency Plan Emergency Response Emergency Response Periodic classroom training and seminars on Emergency Personnel Manager and Response shall be provided on an as-needed basis and at designated staff the discretion of the Emergency Response Manager to these individuals from qualified outside organizations and documentation of this training maintained by the Emergency Response Section.

9-l DBNPS Post-Shutdown Emergency Plan Revision 33IBD 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 Emergencv 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 Plant Manager, and coordinated by the Operations Support Center (OSC) Manager and the Emergency Radiation Protection (RP) Manager. 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 p{an+facifiglareas potentially affected by radiation andlor 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 o

b' Decontamination requirement

h. Communications requirements

9-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 planl_facilities.

d. Isolating and posting of areas in the ptantfuc:ilillwith 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 Plant 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. 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 ofthe 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. The Emergency Plant Manager, under the direction of the Emergency Director, will be responsible at the site for coordinating onsite recovery activities and the return to normal eper"tionsslatus. At the time that an emergency has been terminated, and Recovery has been initiated, the Emergency Offsite Manager will be responsible for providing notification to all applicable agencies (federal, state, count5r, etc.). 9.2.1 Prior to terminating an emergency and entering the Recovery phase, the Emergency Director will coordinate with the Emergency Plant Manager and the Emergency 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, andlor 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 Post-Shutdown Emergency Plan Revision 33TBD

c. +n-p{anlEaqiliqlradiation 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, eentainment pressure is within teehnieal speeifieatiens,

g. The reaeterSll is in a stable safe sMMondition and long-term ee+e spent fuel 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: L. For events of a minor nature, the normal onshift organization should be adequate to perform necessary recovery actions (e.g., for I_INUSUAL EVENT classifi cations).

b. For events involving significant damage to plantsystems required to maintain @Ug, 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 significant damage to @ resulting in a radiological release, a formal Recovery Organization will be established to manage the recovery actions (e.g., for SITE AREA or GENERAL EMERGENCY classifi cations). 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 plaflffasi-Lblhas 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 Post-Shutdown Emergency Plan Revision 33TBD 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 ofthe restoration program is to @ pewerepe+atiensreturn to safe storage of spent fuel. This program will include a detailed incident analysis. Determinations will be made as to the repair work required to perform needed modifications to planlequipment and/or eperating 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:

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. J Coordinate with the CNRB to ensure adequate review of engineering activities and proper review and approval ofthe recovery plan and implementing procedures. 4 Coordinate the deactivations of emergency response facilities and personnel as appropriate. 5 Coordinate the integration ofavailable state and federal assistance into recovery activities. 6 Coordinate with offsite authorities, and provide support as required for offsite recovery activities. 7 Review all information released by the Public Information Organization.

9-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

b. Outage Director:

I Reports to the Recovery Director. 2 Coordinates the development and implementation of the recovery plans and procedures, under the direction ofthe Recovery Director. J 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 planffaSiljqt_radiation suryeys, sampling, and shielding in support of waste system processing, p{antfuiliry repairs, and design modification activities.

6. Designate members of Reentry/Recovery Team(s) dealing with onsite radiological aspects ofthe 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:

l. Reports to the Outage Director.

2. Coordinate the development of plans and procedures in support of plan+SIL systems and eperatisr+.activities.

3. Provide a central point for the collection, retention, retrieval and transmission of plan#acililldata.

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 ptan+fac:ili1y.

e. Operations Manager:

l. Reports to the Outage Director.

2. Direct recovery activities conducted by Operations personnel.

3. Provide recommendations to the Outage Director regarding plan+

SFP operations-related aspects of the recovery.

9-6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

f. Maintenance Manager:

I Reports to the Outage Director. 2 Coordinate maintenance activities conducted in support of recovery. J Designate members of the Reentry team, as appropriate to support maintenance.

g. Offsite Recovery Advisor:

I Reports to the Recovery Director. 2 Provides liaison with offsite agencies and coordinating DBNPS assistance with offsite recovery and assessment efforts, as requested. J, 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:

l. 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 Post-Shutdown Emergency Plan Revision STBD FIGURE 9-1 RECOVERY ORGANIZATION FRAMEWORK Rocovery Director (Emrg6ncy Director) Suppod Group Company Nucloar Review Boad Offsilo Recovery Advisor Oireclor Company SpokespoBon (EmeEency Otfsile Manag6r) Manager) (Company Spokesperson) Opehtions ManaOer Manager (Emsrg Assistant Planl Manager) Manager) Scheduling Manager (RecoveryAdviso0 (TSC Mate&ls Managsr M6intenence Menager (R6soutse Coodinato0 (OSc

A-l DBNPS Post-Shutdown Emergency Plan Revision 33IBD Appendix A POST SHUTDOWN EMERGENCY PLAN PROCEDURE AND RELATED DOCUMENT INDEX AND CROSS-REFERENCE

A-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page I of6 Procedure DBNPS Post-Shutdown Emergency Implementins Procedures Number Plan Section

l. EmergencyClassification RA-EP-o1500 4.1,4.2

2. Unusual Event RA-EP-01600 4.1.4

3. Alert RA-EP-O1700 4.1.3

4. Site Area Emergency RA-EP-O1800 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. EmergencyNotifications RA-EP-02110 6.1.1,7.6

8. EOF Activation and Response RA-EP-02220 5.5.2,6.1.2,7.0,7.2

9. Dose Assessment Center Activation and RA-EP-02230 5.5.2,7.2

Response

10. FENOC MIDAS Dose Assessment Software NOP-LP-s400 6.2 I l. Davis-Besse MIDAS Dose Assessment NOP-LP-s402 6.2 Software

12. DBNPS MIDAS Multiple Accident Dose NOP-LP-5412 6.2 Assessment Software

13. Offsite Dose Assessment RA-EP-02240 6.2

14. Protective Action Guidelines RA-EP-02245 6.4

15. FENOC Field Monitoring Teams Radiation NOP-LP-5o15 6.2,5.5.2 Monitoring Teams Field Surveys

16. DBAB Radiation Monitoring Team RA-EP-02252 6.2,5.5.2 Surveys

17. Radiological Controls in the DBAB RA-EP-02260 6.4.1,6.4.2,7.2

18. Facilities Support RA-EP-02270 7.0

19. TSC Activation and Response RA-EP-02310 5.4.4,7.2

20. Emergency Technical Assessment RA-EP-02320 6.2

21. OSC Activation and Response RA-EP-02410 5.4.5, 6.4.2,7 .7.2

22. Search and Rescue RA-EP-02420 6.4.1

23. Emergency Security Activation and RA-EP-02510 5.3.4,5.4.4,6.4.3

Response

24. Assembly and Accountability RA-EP-02520 6.4.1

25. Evacuation RA-EP-o2s30 6.4.1

26. Offsite Personnel & Vehicle Monitoring & RA-EP-02550 6.4.1 Decontamination

27. Emergency RP Organization Activation RA-EP-02610 5.4.4,5.4.5 and Response

28. Emergency Exposure Control and RA-EP-02620 6.5.1,6.5.2 Potassium Iodide Distribution

29. Station Radiological Surveys and Controls RA-EP-02640 5.4.5,6.5 During Emergencies

30. Reentry RA-EP-02710 9.1

31. Recovery Organization RA-EP-02720 9.2

A-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page2 of 6 Procedure DBI\IPS Post-Shutdown 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-O2800 2.7 Injured Personnel

3. Emergency Helicopter Landing Zone RA-EP-o2807 2.7

4. Tornado RA-EP-02810 2.6.5,2.7,7 .10

5. Earthquake RA-EP-o2820 2.6.5,2 7,7 10

6. Flooding RA-EP-o2830 2.6.5,2 7,7 l0

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 lncidents RA-EP-02861 2.6.5,2.7,7.10 Ma+ien R+EPO28+I W RA-EP-02865

• 1?.1 O.Station Isolation RA-EP-o2870 2.6.5,2.7,7 .10
• Lll-Internal Flooding RA-EP-o2880 2.6.5,2.7,7.10 l+.IZERO Response to Security Events or Threats RA-EP-o2890 2.6.5,2.7,6.4.1 Administrative Procedures

1. Emergency Plan Training Program RA-EP-0o100 2.7, 8.1.1

2. Emergency Response Organization Training NOP-LP-s006 2.7, 8.1.1 Program

3. Emergency Response Drill And Exercise Program NOP-LP-5or 1 2.7,8.1.2

4. Emergency Planning Activity Scheduling RA-EP-00300 2.7 System

5. FENOC Siren Testing And Maintenance NOP-LP-5005 2.7,7 .8 Procedure

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 2.7,9.4 Preventative Maintenance Program I 1. Emergency Facilities Communications RA-EP-04000 2.7,8.1.2 Monthly Test

12. Station Alarm Test RA-EP-04001 )1 8.1.2

13. Communication System Quarterly Test RA-EP-04002 2.7, 8.1.2 1 4. Computerized Automated Notifi cation System RA-EP-04003 2.7, 8.1.2 Weekly Test 1 5. Emergency Facilities Communication RA-EP-04010 2.1,8.1.2 Quarterly Test

A-4 DBNPS Post-Shutdown Emergency Plan Revision STBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 3 of6 Public Information Procedure L JIC Activation and Response RA-EP-02950 2.7, 4.3.3, 5.5,7.2,9.3 Supporting Documents

1. Fleet Support of Emergency Plans at FENOC NOBP-LP-SOO1 8.3, Table 8-1 Nuclear Plants

A-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 4 of6 I\UREG DB Post-Shutdown NTJREG DB Post-Shutdown Emergqq. Emergency. 06s4 to Plan Section 0654 to Plan Section Ala 2.8,5.8,Tabte 2.1 Ftd 7.6 Atb 5.1 - s.8 Fle 6.1.2,7 .6.1 Alc Table2-l Ftf 7.6 Ald 5.2 F2 7 .6.3,7 .8 Ale 5.1.2,5.1.3, Table 5.1 F3 8.1.2 A2a N/A GI 8.2 A2b N/A G2 8.2 A3 App.c G3a 7.3.4 A4 5.0 c3b 7.3.4 B1 5.3 G4a 5.2.4 B2 5.2.1 c4b 5.5,7.3.4 B3 5.2.1,5.3.1-5.3.12_ G4c 7.3.4 B4 5.2.1 G5 8.1.1 B5 5.0, Table 5-l H1 7.2,7.2.2 B6 Figure 6-2 H2 7.2 B7 Table 5-1, 5.6 H3 N/A B7a 7.0 H4 Table 5-1, 7.6.1 B7b 7.2 H5a 7.9 B7c 7.2 Hsb 7.9.6,7.9.8 B7d 7.2 H5c 7.9.9 B8 5.8.4 H5d 7.9.6 B9 5.7, App. C H6a 7.9.8 Cla 5 .2.1 , 6.1 .6 H6b 7.9.11 clb 5.8.3 H6c 7.9.10 Clc 7 .6,7 .9 H7 7.9.11 C2a N/A H8 7.9.6 c2b 5.5.2 H9 7.10 C3 7.9.10-7.9.12 Hl0 7 .12,8.1.3 C4 5.8, App. C H11 6.4.2,7.12 DI N/A (NEr 99-01) Ht2 7.9.10 D2 N/A (NEr ee-01) II 4.0 D3 N/A D4 N/A I2 7.9 EI 6.1,7.6.2 l3a 4.0 8,2 6.1 I3b 4.0 E3 6.1 t4 4.0 8,4 6.0 I5 7 .2,7 .9.8 E5 N/A t6 7.9.8 E6 6.4', I7 7.9.11 8,7 6.4 I8 7.9 Fla 7.6 I9 7.9,Table 7-4 Flb 7.6 It0 7.9 Flc 7.6 I lr N/A

A-6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 5 of6 I\UREG DB Post-Shutdown NIIREG DB Post-Shutdown Emergency. Emergencv. 06s4 to Plan Section 0654 to Plan Section Jla 6.4.1 K6c 6.4.3 Jlb 6.4.1 K7 6.5.3 Jlc 6.4.1 L1 5.8.2, 6.5.4, 6.5.5 Jld 6.4.1 L2 6.s.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-l J6a 7.9 M3 9.2 J7 6.4.1 M4 9.2.3.c.3 J8 App.D Nla 8.1.2 J9 N/A Nlb 8.1.2 J lOa App.D N2a 8.1.2 J tob App.D N2b 8.1.2 J lOc 7.7 N2c 8.1.2 J 10d N/A N2d 8.1.2 J 10e N/A N 2 e(l) 8.1.2 J 10f N/A N 2e (2) 8.1.2 J l0g N/A N3a 8.1.2 J loh N/A N3b 8.1.2 J loi N/A N3c 8.1.2 J loj N/A N3d 8.1.2 J lok N/A N3e 8.t.2 J 101 N/A N3f 8.1.2 J lOm 6.4.1, Table 6-1 thru 6-6 N4 8.1.2 J l1 N/A N5 8.1.2 J12 N/A 01 8.1.1 Kla 6.5.3 0la 8.1.1 Klb 6.5.1 0lb N/A Klc 6.5.1 02 8.1.1,8.1.2 Kld 6.5.3 03 8.1.1, Table 8-l Kle 6.5.3 04a 8.1.1 Krf 6.5.4 04b 8.1.1 Klg 6.5.5 04c 8.1.1 K2 5.2.1,6.5.1 04d 8.1.1 K3a 5.2.1 04e 8.1.1 K3b 6.1 04f 8. r.1 K4 N/A o4e 8.1.1 K5a 6.s.3 04h 8.1 .l Ksb 6.s.3 04i 8.1.1 K6a 6.4.3 04j 8.1.1 K6b 6.4.3 05 8.1.1

A-7 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 6 of6 NT]REG DB Post-Shutdown I\ITIREG DB Post-Shutdown Emergqq, Emerggney' 0654 to Plan Section 0654 to Plan Section PI 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 Pl0 7.6.3

B-1 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Appendix B Department of Energy Emergency Radiological Assistance Program (DOE O 153.1) for FirstEnergy Corporation Davis-Besse Nuclear Power Station (Reference to DOE O 153.1 is available Online at: www.directives.doe.gov)

c-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 ins Ottawa County Commissioners Ohio Department of Public Safety Emergency Management Agency

c-2 DBNPS Post-Shutdown Emergency Plan Revision 33TBD EI}IERGENCY RESPO NSE AG REEMET{T This Agreemd msdc and enlercd inm by and bctvresn PimtEnergy (hcrcimfrm "Utillty') and the Canoll Torruehip Emegc'ncy Msdical artd Firc $onice, Ine, in conslderation of thc follawing: I The Carmll Towuship Emergrncy lvtredical and Flrr $ccvice, Inc., (hcrcinafter *Service, Inc*,') agrces to use equlpmcnt available to it to prulide twenty-four (2a) hour emergenoy ambulanec and fire protestion for actrral emergoneies, including hoetilc action eve,nts il Davis Bffi Powm Staliotr, drills End trainlng activities at FimtEncrgy, located within ttrc jurisdictional boundary of Cqiloll Township, Ottau,B County, Ohio, all subject to the actual emtrgency nesds of ftc uhole Township. When ueccss&ry to provide such actual cmcrgcncy service, licrviet, Inc., will rcqucBl any muhsl aid ar assi,$tatlcq as mey be neoetsary flnd that rnay be availablc fom sunourding cornnrunities.

2. The Utility shall prwids Service, [n0., with any supplies and additional quipmcnt or modifications to current oquipmenr that may be necessary, as dclermined basod upou the mulual agleement of the Utility and $ervioc, Inc,, for $crvicc, [nc., to fulfill im obligations hereundsr or to meet the requircmenls of the Nuclear Regulatory Commi*sion thar nray apply to this Agreernent; if lhe ncccssary equipment is nol provided to $crvicc, Inc,, by Utility, then the obligation* hcrcundcr requirtd of Scrvice, Inc.,

arc waivcd and Serviec, lnc., shnll not be required in any fashion to fulfill the obligations hcrcof, nor slrall Seryicc, Inc., bo lisrble for faiting to fullill said obligptions. Auy equipment provided by the Utility to Suvice, Inc., shall bc slored and msintaincd at lhe discrelion of Scrvice, Inc.' 3  !'urther, the Utility agrees to assume all cxpenses and costs of providing specialized training for pi:rlicipating pcrsomcl nud support personncl as

c-3 DBNPS Post-Shutdown Emergency Plan Revision 33TBD &norgency Rcsponsc AgreEment Page 2

             &slgratcd by Service, Inc,, Thir tmining shlll lnchdf an mnual reyiew of rrcocs$ff y Ernetgenc,y tiltsportfltion proccdur$, cqufurned, supplies, annual fimining Ecssion$ and participqtion in pcriodic emergency drills.

Servicr, Inc., will submit inrroies for reimbursemnt on a time and matcrinl basis whiqh shall be promptly paid to Scrvloe, Irc" by thc Utility. {. Csffoll Tov,,nship Emer8pncy Medical and Fire Servicc, Inc., agrees to make practice run* and/or drills in conjunction with exercises of the emtrgcncy plan as may bc muhrally agreed upo& h'nt such agrecrncnt shall not bo unreasonably wittrtreld.

5. 11 shall be the rryonsibiltf of llhe Utility to protrct and safeguard the peroonrel and equlp:rcrrt of Scrrrice, IrE,, and any mutual aid rcqpondcr$,

liom radialion, The Ulility shall be liable for property damagc to Sc*ice, Irrc., equiprnart and ony bodlly injury to Seruice, Irm., personnel, including duath, that is caused by exposure to radistion during the perforrnance of oblig*tions under the Agreernett. The Utility shall be liuble for aon-radiation related lnjuri* or datnagcs to the e:dsnt caused by i{s ovrn negligencc. The Utility shall promptly repoir or replace Servlce, Inc,, equiprncnt in order to avoid any intemrptlon in firc or ambulance service to lhe cornnrunity. Howeva, in rm event slnll the Utility be requircd to rcplucc or repair any property in excess of its prior thir markct valuc. Fur{her, ThE Utility shall not be liable for any cost of complcte decontamination, repair andlor replacernent of any ptoperiy or non-rndialion rclntod bulily injuy 1o tlte cxtent it is the result of the negligence of thc $ervice, Itc..

c-4 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Emorgcncy Reqponse Agrremeirt Prye 3

6. Frrther, The utility shell indemdry asd hold $erviee, Inc", carloll Torvnship, the Boand of canoll roumship Trustccs, any o,tlrer entitr providing mutual rid rc*poose, snd amy snd all persons asspeiflM with any such orgauizations, harmlers from any and all liability for damages, elrperse, r4iurier or losses ttrnt mey oscur io tlrc fulfillmurt of the obligation* of this Agrwment, exoeFt for non'radiological cmfryrncy arnbulsnce and fire protectiom scrviccs. Thc Utiltqr afrrcsaid indemnity and hold hannlcss agrtcment shsll not bc applicrblc to any linbility caused by th* ssle u$tive negligence of Sewice, Inc., or any othcr mutual ald msponder.

7, There shall bs no charge for tlp rfore,s*id firo putoction; howwer, rhe Utility shall pay the Carroll Tov,'nship Bmrycncy Modical and Fire service, Inc., ihe rate of $Z$o"fr) per lrour, for time fnom call urtil thc ambulance is back in service, for crncr,gcncy anrbulance catls in exces$ of trvr:lve (12) per year,

8. Seruice, Inc., agrccs to provide a staging area for emcrgency equipmcnt and personnel in the cveut the Utility {Davis Besse Nuclear Porver Station) is involycd in a sccurity related elent.

9. 'lhis Agteement shall rcmain in cflcct until terrninated in writing by eithu Farty thirty (30) days p,rior to flre etIccrivc datc.

c-5 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Enrergrncy Responsc Agrcamcnt Pagc 4 FirstEuergy &aotl Toumship Emergency Mcdlcal and Firc $crricg lrrc. By: Davie Besc Nuclcrr By ffilr.tfirilBi0rrtffilc tmdm STATE OF OHrO ) rroilrhicscll$tfi,tflr

                               ) $sr corrNTY or oTTAwA)

Bc it rcmnnbcrcd that on rhi$ 0tt* day of S[rf+rnha(^ . 1014, before me a Nolary Puhlis in and for said Countn petsonally came -Bq=rufid -A", U&-.-. Bn oflicer of FirrtEnergy, rvho apknowledged the rigning of thc ahovc Agrcernent as an Officm of First Encrgy, on bchslf of First tsnugy, and by the authority of its Board of Directoq and that the Agreement is the voluntary act and deed of Irirst linergy and as such Officer, and the voluntary act and dccd of First , for the Burposs$ staled tlrercin. IN TESTITIONY WIIEREOX', I have hereunto subscribed my name and affixed rny scal ttris o)8'1 aayof ..&p[,{rnhr.t- ,, 2014. N -s tate of

c-6 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Emergency Response Agreement Page 5 srarE oF oEIo )

                            ) SS:

corINTv or oTTAwA) Be it remembered that on this

• day of O cJ"L"- 20t4, before me a Notary hrblic in and for said Cormty, personatly came

  ?"f^         $rou  6               and      k^*(, 4owt<l  'I           ,     officers of Caroll Township Emergeucy Medicat sad Firo         ^t.

Urvtce, Iac., vrho acknowledgsd thc sigDing of the above Agreeurent as Officers of Service, [nc., on behalf of Scrviqe, Inc., and by the authority of its Board of Directors, ffid that the Agreenrent is thc voluntary act and deed of ok^ C, md as snch Officers, and the voluntary act and deed of Serrrice, Inc., for purpose$ stated therein. IN TESTIMOITY WHEREOFT I have hereunto subscribed ey name and affixed mY seal this lw day of O.,H,.t .20t4. t ,/,*l tr' Art )urA h"r Ah txfY.+w

c-7 DBNPS Post-Shutdown Emergency Plan Revision 33TBD MAGRUDER 515 Fulmn Stecr HOSPITAL Pur Clinton,Ohio 43452 419-734Jr31 It's How We Care Oobbrlg,2015 Mr. Jsmer Vtter EmerEBncy Rcrponse Manager Oavis- Besrc iluderr Poupr Station 5501State Boutc 1, Mell Stop 3060 Oak Harbor, Ohlo 43449-9750

Dear Mr,

Vcntr: This is to naff,rm our oommitment of l{ovember ld 1972 in that H. 8. Matruder Memorirl llospital will sccept crsualties arising from rrdhtbn iccHnts at tte Darris-Eerg Nud.r powr Station. tt is understood that the FirstEnergy Compary is finenchlly respoaslble for any modifications of the exastirB hospital fadlhy whkh mey b reguircd by rqulatlons of the Nuclcar Rqulatory Commistion, or other, fur the trs.tment of petlents ryosed to ndloec$vc mrterials. This also indudes tralnlng of hospital 6rrcnnet as nay be requlred and br special equipmcnt as may be neosssary. It is further undemood that written procedures detailiq the .ctions to be followed fior the csre of these patients will be implemented and that our peGonnl wltl eontinue to receiw instructlons regarding this plan of action and will male perlodic'dry runt' as nccded. This agreement sh.ll remain in effed untll termlnated in writing by ehher party thirty (30t days prlor to tfte effective date, Slncere!y,

                                                          /ffid{
                                                            .1. Todd Almendinger Presideot & CEO JT{pap

c-8 DBNPS Post-Shutdown Emergency Plan Revision 33TBD R!u, ?3 Fchnry. Zll I rddr* l.trors CouNtY 't'

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c-9 DBNPS Post-Shutdown Emergency Plan Revision 33TBD hrddCutntr Luc*s CouNry Ctnr.nbd3rrrt OrdCotndr Pe$M Ttnr$uNturlfocdrtr IlttCrrlcn tugUqyl{rrfrnurn ASory llanbilvS llcFmm DtftiW [{r. lames Ycttcr Fcfinnry 6b?nn BncAorcyRoqorsc Menqnr DrvirBosrc Nuchr Soruot Shtim 550t N. StanRouo2 Ork Hartu,(}hio 43449 Elcar Mr. Vclta'. Thc &llowing lnulrnl old qgrpotmms rG rvrilebla fs l,rrcrr Corrty lilvlA ln the cwa additioul rorurccr lt ncodod b sultpod t rstpots lo ffi imldonl, inchding lrodilo,oclk a bGGd, d lho Dmd+Bcrrc Nuelcrr Porwr $nha. a Thc Oft io lntn{rlc Muttnl AH Oonrpm oMACI o Tfic grporc of IMAC ir to dovohp md irprcva inhum nuual ald crpablllth: fo,r pwftlhg srvieBr !trd lBlourcicr mroes hcrl bourdrrla in m4otre b and rccorcryfom rrqrdi*rtcrnmltlrry hr frrnd deoleration of oncrpncy. a Emet3ocy Manrgertrtut Araidrms Gsrry.il (8MAC) o Tldr corptel nnr othbliCred by ct*oq ftr fto rtr&t. lt ir rrct r ftdcm! prugrrnr. Tfurt rru, honrnr, gt*anr in the EI,IAC trosrirn nfrich rlh* lbrdm smrdlnrtion wilh fcdonl portncrr cq,gued in ru;rporfing alFcctod C&. t Orlo law &forcffrcnt Rcapmo Phn (l-ERP) o Tho LBRP ir a lool fo hrv onfounonl egpsfui to acquirc hrga qtntililllr of lrw cnfscturenl rc:ourctr in tltc Gvun of I fulrcaic Umri* mrcL nqlor dbrster, or o0rer ansrgarcy, a Ohio ltirc Cl*cfr Asociation Ernorpmy Responr Plur o Dctelopcd by thc olrb Fln Clrlcfr Asociation rs n pkn to brhg rrutual aid to arry arcr ofthe rtrts in rced of additiond Frrc rcepoor roro,uw.

Rogards, Mrllthcrv lloynmn Dircur

c-10 DBNPS Post-Shutdown Emergency Plan Revision 33IBD { Pnotr,tEDrcA MEUONlAI HOSPITAL C)t,r Migsrr:r) rs t0 inrprove your healtlr and well-being, I'lovember 28,20ll Mr.Jrmes M. Vetter Manager - Emergency Preparedness Davis-8esse Nudaar Power Sletlon 5fl11 Stst Route 2, Mail Stop 3050 Oak Harbor, Ohio 4!14{9-9760

Dear Mr,

Vetter, This ktter rcaffirms our corrnltmrnt of lunc 30, 1998 thet ProMedica Memorbl Hospitalwill aeoept casualties arising fmm radiation acciderE st thc Davb-Besse Nudear Power Station. ll ls understod that FlrstEqerty b flnanclally rcsponshle for any modlflcations to the exirting hospitsl facility, which may be requirEd for regulations of the Nuchar Begulatory Commi:sion, orothe6, for the treatment of patients expored to radioactive materiab. This also includes tralnirq of hospital personnel ai may be requlred and for rpedal equlpment as may be necessary" It is further understood that written procedures detailing the actbns to be followed for the carc of these patlnB wlll be lmplemanted and that our personnel will rontinue to rcrelve lnstructlons rgardlru thls plan of actlon and wlll make perlodlc'dry runs: as needed. This agreement shall remaln in effect until termlnated in wriUng by ehher party thirty (30) days prior to the effiective date. Sincerely, Pam Jensen, ProMedica Memorial Hospital

c-l I DBNPS Post-Shutdown Emergency Plan Revision STBD

 /"aMnncv (irrc !'ort mn hdim in?

Mry{:, l;'1. Att lkrsdli tr'{tr:e i;1. O}*1% Hollilit: July 29, l0l$ vll*erf i,tsjtrl $o.:er lJrrr.} 51. Mr. James M. Velter ldeiri Cfrtl Brt Ho$tllu Manager - Emenency Rt$lnsc ly':rf,t }loiptij a{ Cl,{iril# Davis-Besse l{ucltar Fosr Statlon 55Ol N. StatE Route 2, MallStop 31160 ldrft lmr] !,rqCi;J oal Harbor oH {3'149-9760 ly'irt 'r!,hrr- His{Iir, MRc),L'!'l jr l'Artrtr Detr Mr.Vetler: This terter of Agreement rtafffrms our commitnent, spcrifted ln Our mutud a&eefient with Firn EncrEV, thet Mercy St. Charler Horpttal will accept G.suehict arblrg lrom radlalbn acddcnts at dre Davis-Besse Nudear Power Statbn' It ir understood that Flllt Entgy ii f,nafthh responsblc for any rnodiffcrtbrc of the exbt'rg hospltat hcility whlch may te regulred by regulatlofls orotter guidancc of tlte Nudear Regulabry commbrbn (ilBC) orthe Federal Emeryency Mrnagemettt Ate]lcy (FEMAI for the trEatmclfr of patl6ntt enosed to ndiracthe matGrisB. TI1E also lnc'ludcs tralnlng of hospital personnel rs may be raquired, atd for sfdel aqdprnent ai m.y b. nccessary. It b furtlrer undeEtood thet written prooedures detalllng the actlons to be follored forthe care of these paE-ents will be lmphmentcd and that our penonnel wlll contkrue to rcoeivc l$tructions regardirg thls plan of rtion and will make perlodk "dry runf ar necded. This agreement shall rtmdn ln effeet umil terminattd h writing by clther parry thlrty (30) dryr prior to the effecttue date. Slncerely,

                                                                    ,4/t^^4)

CralE Albers, Iil Vlce Presldent, Patient GrelCNO Mercy St. Orarles HosPttal Agrced to: g-9ff' M- Vetter Date

                                                      , Emergency Besponse DavJs-8e5se Nuclear Povrer Statlon

c-12 DBNPS Post-Shutdown Emergency Plan Revision 33TBD

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TlOt$4&e0 FAXTt*{,1,lW7 Oet$cf 30, 2012 Dcat Indle and Cc,ntlcrnm: lltl* lctlcr cfftlfh tbrt the plant emeryemcl, *s$astanse rgemcnt betrve$ INPO and ls msmlsr utllltlss rcmillns ln cffset Inthe ewrlt of !n srnsi&Ency Bt yirur udlity,IHFO wiH lssist you in aoqriring ths hclp of oilrorcrganiznlions in ths idustry, ae de$Gribd in Srclion I oflhn Bmorgsttcy fusumns lv1anual,INPO 03-001, Effl h lhoUnitcd Statcg Nuotrear Indusky R*qponse ?rrunsnmrk lfroqucrtod, NPO will providc ilrr {bllowing sssislflnec: r soerdinfltc tcshnical infrnrnrti*rt flon, Iiom thg $Ifcsted ulillty tothe nurlcsr irdgrey s$d gerc$rtuent agondes r coardinate lho procurnnrcnt and Cripping of cquipncnt and cupplics r loc*tc Fsmortncl rr,lft ac$hnical cxpertko r lhoililate indrutry yendor and uomrnercial supplier ruport e obtxin tsdmical ir:funnation and industr;,opclatiry oxporiencc rcgording phnt componcnts and syrtonn

     . providc nn II{PO liaison to lhcilit*tc irilcrfncc Thir ngrermunt will rcrnain in cfflerl unlil tenninrrled ln urllinS, Shuuld you havc nny quatllolm, pleune crll $twc Mcng $t(770) 644-8548 or e'mnil rt MrrrgStff@lnpo.org,
                                                                    $incetely, Vice l1'ccidcrr*

Errrcrgorcy Rcsponsc .I'lti:cjm

c-13 DBNPS Post-Shutdown Emergency Plan Revision 33TBD Othuna

                              -Cortly Emcrycnca Manrgpmcnl Agenry                           offic$        {t?-R+69m 315  Madtson Strecl, Annex Basement                                   CounDrytdc: 800-ru8{803 Itrl Clnlon, Ohl0,l345r- tr36                                         Frc$mllc: ttr-2t9.2361 l   i. i.1.,

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Sepembcrtl.l0l4 nrt. rirne! Vfitef. I rlltrf,G]tcy Br,+onr* Minrg[r Dadr'Bcga Nwhrr Founr Stctbn 5501 l'lorth Statr Rorx.2 O6k tLrbor, OH 43149 D,eal Mr, Vettet. Iltc Ollrrrrs Cmnty [mcrycncy Mrnrg,Hrrent Ageftcy l* the lead rgstry ]n ott ryd Countf lbr hrrrdlng and coordlnathg re$onse to area-ullde emerBrtB,er wlthln the Courriy. Ar rud\ th+ Otttuo Cotmty tfier8sncy lllelra8Emenl Agncy rrouH had and cmrdlnale CEttotf mryonre to an incLlent ar lhe Dovls-8esm ltuchar PoHrr Stathn, oltef,,r County har det,lopEd planr md guidtlirxs to deal wlth an erhertency at Oruf+Besse l{udear Power $tatlon, hcludlng hosrlh ectiofi, and would ilqllomrfit thoie pl0fir rnd juirlollnfi to thi bcct of Its ablllty ln thee,rcat of an hddent ot tle pltnt, T] Courrtf, hterds lo ,rotect the heelth 3ld welf*rp ol tlc people in Otliwr Coutly ilrmugh the lmplementnllofi of lls rerponcc plam ord 6uldellnes, IhB lcttcr ol egreomrnl lr not lntwdcd, rnd *hnll nol b? cotlitrued er tterHrg Esbnlry on thc prrt o{ lhe Cnunty of Otlawa, and of lts aEemler, or of ths orlkert, aEe&s sr erybtrrs ttrereof. Thlt a3ttamcnt wlll bo rnrltwed rn4 l{ nrcor*ory, rcvtxd on en rnnurl bash ln aocordrnce yrltlr llUBt6-06S4, lf no reul$onr Me ner4rsiry, lhb agrearnant wlll romnh ln *ffecl unlcrs t*rmlnrted by eilher party gfulnE nlnetf (901 days adtance, rvritlen nptlce of lermlnatlon to the other parly, EOAND OF OI TAWA COUf{ IY COMMISSl0ilTBS OTT,\V/A COUHW EM ERtrITCY MAI.IAG EMTHT itlL,tfu*i.,, #J,,,rrl 4orllen ltegal, Pierlilent ilre<l Peterrpn. EMA llrer.tor esM u:" mls+iontr

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c-14 DBNPS Post-Shutdown Emergency Plan Revision 33TBD OHIo OEpAETMENT &fttrR a(*hrf Oorrnr OF PUBLIC SAFETY qNt. aadraa,ra&A?-. eA.oqlrtl{finAtmsy &asttaOIEE t Srn qrtrlradEf *rh a OibdqffilJuhBrfr. elt.lgrq tlilrgrtlrf f0rEy t ot&Hf,ilffiftqrT, 2l5g yYilt htr.rrr} nOd OHolfiE lEilrEtla Oolrllh[, Oli lltiU$iziB Ot58t{B HtiEf FElt lllil ct&7tr{r w.{ildlb{oy Docembcr2,2013 Mr. Glenn MsKo6 _l_ First Eoqry NrrharQemting Corpuny i 3'll lVhits Pond Driw (IVAC B.I) Akron, Ohio 44320

Dear Mr. McKoo:

In ordBr for drc Sutc of Ohio to rcmein in somptinnso wifi Fedflt rcguhdoos, ths artablirhed Mcmonndum of Undctstanding (MOU) botr*osr the Sttre of Ohio md Firrt f"*gr Nnclcar Opcrating 9onnary tgmqCl hrf be1 rwierrcd rcgrding tle ooordinatioa of off-rlts r*pon u ti-o,rlsr incidom fr leaver-Jellcy Po*rr Stetion (BYPS), Dsvie-BBse Nuclcr Ponrur Strtion fOArypSl ud Perry Nustsar Po'worPlant ([I'IPP). Thc rpurneot is ia rcoordeocc erffi thc Nuchr R.ogularory Commicsion flg1C) *a Fcdoral Emergcncy Manrgrcrnenl Agency (FEMA) guidancc er orrlinod in UuhfS+CSffieMA{Ef-t, Itcr.ision l. Enulosed pu will lind r eopy of tto rnost rcoent docummt T}c prpose of this letlcr is to inform l,ou dre rgrccm.nt bcturocn thc Stato of Ohio 3rd &e fENOC utl tpvie*td and rtaraios in cffcrt, Ths Ststa fifihrackooulodgos thc MOU will ooutinro io rrmdn in full foroc ard effect uotil gugh titnc as gither of tic prtics dccidcs thc ngrsmeot noodr to be rcvire4 Each yeor, thc MOU xill be rcvicnmd for substsntivo chrngar aod updated-as rcoessary. Bening rny suU*untre ehangcs, the Mou win rc,nra:in in elfeot signatory confmration irr nol roquirud.

           -llWu    do not aerro                              s fidr this rcvicw pmccss wish to mrke changEs to thc MOU, plcar contact Mr.

Bear of nry staff *.614:799-3687, If the procoss is ecocprablo uri pu hovc oo cf,*gor, you ueed to Yi"tt*! do nolhing. Plcase let us know iflou have eny questions in lhis rrgud. zt anr plr. Sinoerely, n

                                                                       'd?r<j Erccutivs Diroctor Inclcsuro

c-15 DBNPS Post-Shutdown Emergency Plan Revision 33TBD LETTM. OT AGRUEMTITTT BETWIEN EINSr ENENGY NU([,&[fl, OPENATING COMTANff AITI} TEE OMO DEPARTIUMI{T OT PIIBLIC $ATETY EI}ffi RGINCY ]WANACEMENT AGEIICY Thic lctta will mrve ae a uritten agrumort lhflt thc Firit Bnsrgyldrclauoe&afiry ftarprry (DavlrScaco l*rclearlormor St*iom, Fary Xuotear Powcr 315t, nra nea*,i vau{ poil& SFfm) will povide the Ohio Depaffinmt ofPublic $rftty, pdgcmsy lr,trugEa;t Ag6cy

    *it th, following equipmcat at trc loccionc iudioated drrlqg r aiir oi    *ogi*"y ir*ffioe .

nucloapowcplant.

   !OC. ATION:    EOUPMBNT JPIC: Telephones, frqsimlle lvlilhitrE, Coptcr, Typcurritcr/$rorit Processor, Work Spacc, St1tus Boads, h{ryo, Administrutive SupportffirrpHcr ECCIBOF: Trlcphoneq Facaimilo Macfuins, copicr, Tiro,r* space, staure Bords, Mapq, Admiuighetivc SupportAiupplics NOTE: It ia mdffitood tlut tbis liat ia Dot all inslusivc, but ie ruprasoutativc of the tcvcl of suppod   nedd by rcspondars to these fasilitios A locludcal liaison pill be dispatched by tha Firsffinecgr Nrrclcer Operaring Company to the Stala Emergency Operdions Curtor (EOC) upon orbcfuro ths doolrdion of a Siie Arca Emergmcy at Davis-Bmse NuclrPowu Station, Pmy Nucloar Powa Plurt, or Beaver Valloy Powtr Station as dctsrminEd by individual plant proccdures. The Ststr srill govide similar equipmerrt to the tec}nieal liaiem to Err.sure his/her dullos may bo perfo,rmed. In the evcnt of an incide,nt whtrc  furtherdegradationofthaplut Eppcaru likcln ecbhio Ernor;gcncy          lr,Ianageirrent Agwtcy may rcquest that the tecftnical liaison be disp#hed to thc State EOC prior to e Site Ara Emcrgency dcclaratioa. Ths Ohio Bmergancy Managcmmrt AgEocy wiil dicpitc,h a liaieon to the nuclear powo plant of ooncenr at the Alert lqtel, This agreement slrall be reviewod annually aod updated as ncccessry. The agreerueut will rcmain in effcct until terniinatd by ei&o party through the cuhniasion of a sixty (60) days uriUtm notice.

SIGNED For the State of OIrIo Emergency For fhe Fimt Buergy Nuclear Manrgement Ageuey Operating Compauy _,-.-EJ(PCUTTVE DIRECTOR cBrEr@ a 0 r,ATE

D-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD 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 FTINCTION #IO, HAZARDOUS MATERIALS, TAB B _ REP INCIDENT RESPONSE PLAN OTTAWA COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN LUCAS COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN

E-l DBNPS Post-Shutdown Emergency Plan Revision 33TBD Appendix E (Under Separate Cover) DBRM-EMER-l5O0 A, Davis-Besse Emergency Action Level Basis Document

F-1 DBNPS Post-Shutdown Emergency Plan Revision 33IBD Appendix F (Under Separate Cover) Davis-Besse Nuclear Power Station (DBNPS) ERO Post-Shutdown On-Shift Staffing Analysis Report

Attachment 3 Proposed Revisions to the DBNPS Emergency Plan, Revision 33 (Clean Version) (183 Pages Follow)

DBNPS Post-Shutdown Emergency Plan Revision TBD DAVIS.BESSE NUCLEARPOWER STATION POST-SHUTDOWN EMERGENCY PLAN

DBNPS Post-Shutdown Emergency Plan Revision TBD FOREWORI) 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 Post-Shutdown 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 TBD of the Post-Shutdown Emergency Plan meets the requirements of 10 CFR 50.54(fl. Changes made in Revision TBD do not decrease its effectiveness. The Plan has been revised in accordance with NRC Safety Evaluation [TBD]. The issuance and control of this Post-Shutdown Emergency Plan and activities associated with Emergency Response at the Davis-Besse Nuclear Power Station are the responsibility of the General Plant Manager. Additions, deletions, or modifications to the Post-Shutdown Emergency Plan shall be approved by the Emergency Response Manager and the General Plant Manager. It is intended that this Post-Shutdown Emergency Plan and the Emergency Plan Procedures be fully compatible with the applicable requirements for quality assurance set forth in the FENOC Nuclear Assurance Program Manual. The Emergency Response Manager is hereby assigned the responsibility for emergency preparedness operations with authority as established in this Post-Shutdown Emergency Plan and outlined above. Day-to-day maintenance and implementation of the Emergency Response Program is the responsibility of the Emergency Response Manager and the Emergency Response Section. Emergency Response Manager Date General Plant Manager Date

DBNPS Post-Shutdown Emergency Plan Revision TBD Davis-Besse Nuclear Power Station Post-Shutdown Bmergency Plan Revision TBD Summar.v of Plan Changes Full revision to address implementation of the Post-Shutdown Emergency Plan. No revision bars are used to identiff the changes. The changes to the on-shift and augmented Emergency Response Organization staffing support the permanent cessation of power operations of the Davis-Besse Nuclear Power Station and the permanent removal of fuel from the reactor vessel. 1l

DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE OF CONTENTS Plan Section Topic Page 1.0 DEFINITIONS l-l 2.0 SCOPE AND APPLICABILITY 2-l 2.1 SiteDescription.............. 2-l 2.2 PopulationDistribution a.l L-L 2.3 Emergency Planning Zones 2-3 2.4 Regulatory Requirements................. 2-3 2.5 Objectives of Emergency Response 2-4 2.6 EmergencyPlanlnterrelationships 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 POST.SHUTDOWN EMERGENCY PLAN..... 3-l 3.1 Post-Shutdown Emergency Plan Steps. 3-l 3 .2 Emergency Organizations ..................... 3-l 3.2.1 StateofOhio................ 3-2 3.2.2 Ottawa County, Ohio ............... 3-2 3.2.3 Lucas County, Ohio ................. J-J 3.2.4 Erie County, Ohio J-J 3.2.5 Sandusky County, Ohio ........... J-J 3.2.6 State of Michigan.......... J-J 3.2.7 Federal Agencies.... 3-4 3.3 EmergencyCategories 3-4 llt

DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE OF CONTENTS Plan Section Topic Page 4.0 EMERGENCYCONDITIONS 4-l 4.1 Emergency Classification Levels (ECLs) .....4-l 4.1.1 GENERALEMERGENCY 4-l 4.1.2 SITE AREA EMERGENCY ,..,...,...4-l 4.1.3 ALERT ....4-l 4.1.4 T]NUSUAL EVENT ....4-l 4.1.5 RECOVERY 4-2 4.2 EMERGENCY CLASSIFICATION 4-2 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) 4-3 4.4.1 Deleted ....4-3 4.4.2 Deleted 4-3 4.4.3 Deleted ....4-4 4.4.4 Treatment of Multiple Events and Classification Level Upgrading..4-4 4.4.5 Emergency Classification Level Downgrading ................ .................4-4 4.4.6 Classiffing Transient Events ....4-4 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES .....................5-1 5.1 DBNPS Organization.................

5. I . I Facility Management and Administrative Organization ... 5-1 5.1.2 Onshift Operations Group......... ...5-2 lv

DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE OF CONTENTS Plan Section Topic Page

5. 1.3 Normal Facility Shift Staffing........... 5-2 5.2 DBNPS Emergency Management...., 5-4 5.2.1 EmergencyDirector 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 Deleted 5-6 5.3 Onshift Emergency Response Organization ............. 5-6 5.3.1 Shift Manager................ ........ 5-6 5.3.2 Deleted 5-7 5.3.3 Deleted 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-l I 5.5 Near Site Emergency Response Facility...... ..5-14 5.5.1 Overview... .. s-14 5.5.2 Emergency Operations Facility (EOF) Organization..... 5-l 5

DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE OF CONTENTS Plan Section Topic Page 5.6 Joint Information Center (JIC)........... ...5-17 5.7 Corporate Assistance Center (CAC)........ ..5-17 5.8 Supporting Emergency Organizations ........................ .. 5-18 5.8.1 Letters ofAgreement ............... .. s-18 5.8.2 Medical Emergency Response Organi2ation .................... 5-l 8 5.8.3 Government Agency Support..... 5-21 5.8.4 Other Support Organi2ations .................... 5-27 6.0 EMERGENCY MEASURES 6-1 6.1 Activation of the Emergency Response Organi2ations..................... ..........6-1 6.1.1 Shift Manager/Control Room Operations ....... ..........6-2 6.1.2 EmergencyDirector ..........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 vl

DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE OF CONTENTS Plan Section Topic Page 6.3 Mitigative Actions 6-8 6.4 Protective Actions 6-8 6.4.1 Facility Protective Actions. 6-8 6.4.2 Offsite Protective Actions.. 6-10 6.4.3 Use of Onsite Protective Equipment and Supplies.......................... 6-l I 6.4.4 ContaminationControl Measures 6-1 I 6.4.5 Ingestion Pathway Control Measures 6-1 1 6.5 Aid to Affected Personnel... .................6-l l 6.5.1 Emergency Personnel Exposure.... .............6-11 6.5.3 Decontamination and First Aid.... .............. 6-13 6.5.4 Medical Transportation 6-14 6.5.5 Medical Treatment....... 6-14 7 .O EMERGENCY FACILITIES AND EQUIPMENT................ 7-l 7.1 DBNPS In-Plant Emergency Facilities 7-l 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 Communications Systems................. .....7-7 7.7 Alarms ....7-9 7.8 Prompt Notification System........... ..7-r0 vll

DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE OF CONTENTS Plan Section Topic Page 7.9 AssessmentFacilities 7-tt

7. 1 0 Protective Facilities and Equipment ........ 7-r7 7.11 First Aid and Medical Facilities.. 7-17 7.12 Damage Control Equipment.. 7-18 8.0 MAINTENANCE OF EMERGENCY PREPAREDNESS ...8-l 8.1 Organizational Preparedness..................... ...8-l 8.1.1 Training..... ...8-1 8.1.2 Drills and Exercises ...8-2 8.1.3 Emergency Response Manager.... ...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-l 9.2 Recovery ..9-2 v11l

DBNPS Post-Shutdown Emergency Plan Revision TBD 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 FirstEnergy Corporation - Davis-Besse Nuclear Power Station C Letters of Agreement D Supporting Documents (Under Separate Cover) E DBRM-EMER-l500 A, Davis-Besse Nuclear Power Station Emergency Action Level Basis Document F Davis-Besse Nuclear Power Station (DBNPS) ERO Post-Shutdown On-Shift Staffing Analysis Report lx

DBNPS Post-Shutdown Emergency Plan Revision TBD LIST OF TABLES Plan Tables Title Page 1-1 Acronyms..... ............... 1-1 I t-2 Communications Test Frequencies ........ l-15 2-r Functional Interrelationships of Response Organizations... 2-7 3-l Emergency Categories and the Degree of Participation by Various Groups 3-5 4-l Deleted 5-l Manpower, Location, and Response Considerations for Emergencies... 5-29 6-l 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 ............... 6-1 8 6-5 Representative Shielding Factors for Surface Deposited Radionuclides ............... 6-19 6-6 Guidelines for Protection Against Ingestion of Contamination.... 6-20 7-l Radiation Monitoring lnstruments and Equipment ....................... .....7-19 8-l Periodic Training of Emergency Response Personnel .....8-10 x

DBNPS Post-Shutdown Emergency Plan Revision TBD LIST OF FIGURES Plan Figures Title Page 2-l DBNPS General Site Location.............. ....2-8 2-2 DBNPS Site Annual Wind Distributions at the 10 Meter Leve1..........................2-9 2-3 DBNPS l0-Mile Emergency Planning Zone... ...2-10 2-4 DBNPS 50-Mile Emergency Planning Zone... ...2-tl 5- I Onshift Emergency Organization .................... .. s-31 5 -2 Emergency Response Organization................. ..5-32 6-l Summary of Typical Emergency Measures..... ..6-22 6-2 EmergencyNotification ..6-26 6-3 Offsite Emergency Evacuation Routes............ ..6-28 7-l Emergency Facilities by General Location ..... ..7-21 9-l Recovery Organization Framework.. 9-7 xl

l-1 DBNPS Post-Shutdown Emergency Plan Revision TBD I.O DEFINITIONS Listed below are terms and their definitions as used in the Post-Shutdown Emergency Plan. Defined terms associated with the Emergency Action Levels in Appendix E are shown in ALL UPPER CASE LETTERS. l.l 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 acfual 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 facility status information to individuals who are knowledgeable of, and responsible for engineering and management support of SFP 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 Facilitv 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 Companv Licensee as described in the Davis-Besse Nuclear Power Station NRC Operating License No. NPF-3. 1.9 Compensatory lndications Plant Process Computer, SPDS, and PI Data (Process Book). 1.10 CONFINEMENT BOTINDARY 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 BOLINDARY is defined as the Dry Shielded Canister (DSC).

t-2 DBNPS Post-Shutdown Emergency Plan Revision TBD l.l I Contaminated Area An area where removable contamination exists at levels in excess of 1000 dpm/l0Ocm2 beta gamma or 20 dpm/l00cm2 alpha. 1.12 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. l.l3 Controlled Release Any release of radioactive material from Davis-Besse Nuclear Power Station to the environment, which is planned, deliberate, monitored and regulated. t.t4 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. l.t5 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. l.l6 Drill A supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. r.t1 EMERGENCY ACTTON LEVEL (EAL) A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the facility in a given emergency classification level. I.18 EMERGENCY CLASSIFICATION LEVEL GCL) 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 (l) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are: o Unusual Event (UE) o Alert (A) o Site Area Emergency (SAE) o General Emergency (GE) l.19 Emergency Operations Facilitv (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. 1.20 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.

l-3 DBNPS Post-Shutdown Emergency Plan Revision TBD l.2l Post-Shutdown Emergency Plan The document, which describes the Company philosophy and organization for implementation of regulations dealing with a response to a radiological accident at the Davis-Besse Nuclear Power Station. 1.22 Emergencv Plan Procedures Those procedures which implement the Post-Shutdown Emergency Plan and are maintained by the Emergency Response Section. They include the Emergency Plan Implementing Procedures, Off-Normal Occurrence Procedures, and Administrative Procedures. 1.23 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 l0 miles for a Plume Exposure Pathway; and the other, with a radius of 50 miles for an lngestion Exposure Pathway. In these zones, predetermined Protective Action plans are needed. 1.24 EPA PROTECTTVE ACTION GUTDELINES Environment Protection Agency Protective Action Guidelines. The EPA PAGs are expressed in terms of dose commitment: I 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. 1.25 EssentialPersonnel Those assigned specific emergency response duties as identified in the Post-Shutdown Emergency Plan. 1.26 Exclusion Area The area surrounding the facility 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 ll2 mile) to approximately 1 mile. 1.27 Exercise An event that tests the integrated capability and a major portion of the basic elements within the Post-Shutdown Emergency Plan.

t-4 DBNPS Post-Shutdown Emergency Plan Revision TBD I.28 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. 1.29 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. I.3O 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. l.3l 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 verifu the capability to respond to the accident scenario. (10CFR50, Appendix E, IV.F.2.a) 1.32 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. t.33 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. 1.34 High Radiation Area Any area, accessible to individuals, in which radiation levels could result in an individual receiving in excess ofO.l rem in one hour at 30 cm from the radiation source or from any surface the radiation penetrates. 1.35 HOSTAGE A person(s) held as leverage against the station to ensure that demands will be met by the station. 1.36 HOSTILE ACTION An act toward a nuclear power plant or its personnel that includes the use of violent force

l-5 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 satisfr the overall intent may be included. HOSTILE ACTION should not be construed to include acts ofcivil disobedience or felonious acts that are not part ofa 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). 1.37 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. 1.38 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. 1.39 TMPEpE(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). I.4O INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSD A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. 1.41 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.

1.42 INITIATING flc) An event or condition that aligns with the definition of one of the four emergency classification levels by virtue ofthe potential or actual effects or consequences. 1.43 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. 1.44 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.

1-6 DBNPS Post-Shutdown Emergency Plan Revision TBD 1.45 Loss A state of inoperability in which Functional and Operable status cannot be maintained. 1.46 Low Population Zone The unrestricted area outside the OWNER CONTROLLED AREA, encompassed within a radius of 2 miles (approximately 3200 meters) from the site. 1.47 MAINTAIN Take appropriate action to hold the value of an identified parameter within specified limits. 1.48 MitigativeActions 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). 1.49 Modes of Discharge Discharge of radioactivity to the ground surface, surface water, atmosphere, or any combination thereof. 1.50 News Statement A detailed statement in printed format intended for public knowledge containing an announcement, supporting information, and usually some background information. 1.51 Non-essentialPersonnel Personnel who are not pre-assigned specific emergency response duties 1.52 Normal Levels The highest reading in the past twenty-four hours excluding the current peak value. 1.53 Nuclear Group The functional area of the Company which operates and maintains all nuclear generating facilities owned by or licensed to the Company. 1.54 Offsite Any area outside the OWNER CONTROLLED AREA. 1.55 Onsite The area within the OWNER CONTROLLED AREA 1.56 OperableiOperabilitv 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). 1.57 Operations Support Center A location within the PROTECTED AREA where emergency response teams are assembled, briefed and coordinated during an emergency.

t-7 DBNPS Post-Shutdown Emergency Plan Revision TBD I.58 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. 1.59 PartialParticipation 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.o) 1.60 PersonnelDosimetry 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.]. 1.61 Plume Exposure Pathway The means by which a radioactive cloud (plume) can expose the Population At fusk 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, lnhalation exposure from the passing radioactive plume. 1.62 Population At Risk Those persons for whom Protective Actions are being or would be taken. 1.63 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 airbome 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. 1.64 PROJECTILE An object directed toward a nuclear power plant that could cause concern for its continued operabi I ity, re I iabi I ity, or personnel safety. t.65 PROTECTED AREA An area that normally encompasses all controlled areas within the security protected area fence.

l-8 DBNPS Post-Shutdown Emergency Plan Revision TBD 1.66 ProtectiveActions 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. 1.67 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. 1.68 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 I hour at 30 cm from the radiation source or from any surface the radiation penetrates. 1.69 Radiation Work Permit A document which gives radiation protection requirements, authorization to enter the radiologically controlled area, and permission to receive radiation dose. 1.70 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. t.7t 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. 1.72 Recovery Actions Those actions taken after an emergency to restore the station as nearly as possible to pre-emergency conditions. 1.73 Release A radiological release (airborne or liquid) to the outside environment athibutable to the emergency event. 1.74 RESTORE Take the appropriate action required to return the value of an identified parameter to the applicable limits. 1.75 Safetv Parameter Displa), System (SPDS) - A computer system that acquires and displays facility data. This system provides data to Operator Aids. 1,76 SECURITYCONDITION Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threaUrisk to site personnel, or a potential degradation

l-9 DBNPS Post-Shutdown Emergency Plan Revision TBD to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. 1.77 Shift Manager's Office A facility that is located within the Control Room envelope and may be used by the Emergency Assistant Plant Manager during emergency conditions to observe and provide guidance to the Shift Manager for direction and control of facility activities. I.78 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: l) 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. 1.79 SITE BOTINDARY 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. 1.80 State The State of Ohio l.8l Technical Support Center (TSC) An area within the OWNER CONTROLLED AREA, which has the capability to display and transmit facility status information to individuals who are knowledgeable of, and responsible for engineering and management support of SFP operations in the event of an emergency situation. 1.82 UncontrolledRelease 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. I.83 UNISOLABLE An open or breached system line that cannot be isolated, remotely or locally. 1.84 UNPLANNED A parameter change or an event that is not l) the result of an intended evolution or 2\ an expected facility response to a transient. The cause of the parameter change or event may be known or unknown.

l-10 DBNPS Post-Shutdown Emergency Plan Revision TBD I.85 LINUSUAL 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. I.86 VALID An indication, report, or condition, is considered to be VALID when it is verified by: l) an instrument channel check, 2) indications on related or redundant indicators, or 3) by direct observation by facility personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. 1.87 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. 1.88 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.

l-l I DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 1.1 ACROIYYMS AC Alternating Current ATSC Alternate Technical Support Center ALARA As Low As is Reasonably Achievable ARM Area Radiation Monitor B&W Babcock and Wilcox CA Controls Area (in control room) CAC Corporate Assistance Center CAM Continuous Air Monitor CANS Computerized Automated Notification System CAS Central Alarm Station CDE Committed Dose Equivalent CE Combustion Engineering CFH Certified Fuel Handler CFR Code of Federal Regulations CNRB Company Nuclear Review Board CRM Containment Radiation Monitor CTRM Control Room cpm counts per minute DADS Data Acquisition and Display System DBAB Davis-Besse Administration Building DBABA Davis-Besse Administration Building Annex DBNPS Davis-Besse Nuclear Power Station DC Direct Current DFSF Dry Fuel Storage Facility DOE Department of Energy DOT Department of Transportation DPM Decades Per Minute dpm disintegration' s per minute E&C Electrical and Controls EAL Emergency Action Level EAS Emergency Alert System ECL Emergency Classifi cation Level ED Emergency Director

t-12 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 1-1 ACROI\TYMS EEC Energy Education Center EMA Emergency Management Agency ENS Emergency Notification System (NRC "red phone") EOC Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure EPZ Emergency Planning Zone ERO Emergency Response Organization FBI Federal Bureau of lnvestigation FE FirstEnergy Corporation FEMA Federal Emergency Management Agency FENOC FirstEnergy Nuclear Operating Company FSAR Final Safety Analysis Report GE General Emergency I{PN Health Physics Network IC Initiating Condition I&C lnstrument and Control IGLD International Great Lakes Datum ISFSI Independent Spent Fuel Storage Installation JIC Joint Information Center Keff Effective Neutron Multiplication Factor LCEMA Lucas County Emergency Management Agency LCO Limiting Conditions for Operation LDE Lens Dose Equivalent mR milliRoentgen

1-13 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 1.1 ACROI\TYMS MW Megawatt MWe Megawatt electric MWt Megawatt thermal NCO Non-Certified Operator NEI Nuclear Energy Institute NOAA National Oceanographic and Atmospheric Administration NOUE Notification Of Unusual Event NPP Nuclear Power Plant NRC Nuclear Regulatory Commission 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 PA Protected Area PAG Protective Action Guide PASS Post Accident Sampling System (see ARCSS) PNS Prompt Notification System (siren system) PSIG Pounds per Square Inch Gauge R Roentgen RCA Radiologically Controlled Area REM Roentgen Equivalent Man REMP Radiological Environmental Monitoring Program RMT Radiation Monitoring Team RP Radiation Protection

t-14 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 1-1 ACROIYYMS RTL Radiological Testing Lab RWP Radiation Work Permit SAS Secondary Alarm Station SCBA Self-Contained Breathing Apparatus SDE Shallow Dose Equivalent SFP Spent Fuel Pool SPDS Safety Parameter Display System SSE Safe Shutdown Earthquake TEDE Total Effective Dose Equivalent TRM Technical Requirements Manual TSC Technical Support Center UE Unusual Event USAR Updated Safety Analysis Report VDC Volts DC WE Westinghouse Electric woG Westinghouse Owners Group

1-1 5 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 1-2 COMMUNICATIONS TEST FREOUENCIES 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-l DBNPS Post-Shutdown Emergency Plan Revision TBD 2,0 SCOPE AND APPLICABILITY The Davis-Besse Nuclear Power Station Post-Shutdown 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 Post-Shutdown Emergency Plan is a detailed expansion of the Updated Safety Analysis Report, Section 13.3. It is intended to satisfu the requirements of Title l0 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/f'EUa REP. l, Rev. l, Criteria for Preparation and Evaluation of Radiological Emergenc), Response Plans and Preparedness in Support of Nuclear Power Plants. This Post-Shutdown Emergency Plan is not the primary working document to be used during an emergency. The purpose of the Post-Shutdown Emergency Plan is to describe the program established at DBNPS to satisff regulatory requirements and to safeguard the public and facility personnel in the event ofan 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 formerly employed a pressurized light water reactor steam supply system furnished by the Babcock & Wilcox Co. (now AREVA NP) to generate approximately 930 MWe. The reactor design core power was 2817 MWt. The reactor permanently ceased power operations on IDATE] and was permanently defueled on [DATE]. Spent Fuel is stored in the Spent Fuel Pool (SFP) and the Independent Spent Fuel Storage Installation (ISFSI). 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 Post-Shutdown Emergency Plan Revision TBD 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 l0 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 seryes 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 System's 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 PopulationDistribution 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/f'EVtR Rev.-1, Appendix 4. The near-site population is distributed from the southeast to the west northwest. The total permanent population in the lO-mile area surrounding DBNPS, based on 2010 Census information is 20,403 people. Approximately 89%o 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 l0 mile, and l0 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/f'EUa Rev.-1, Appendix 4. TheEPZ permanent resident population is reviewed annually. If at any time during the decennial period theEPZ 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 l0-mileEPZ to increase by 25 percent or 30 minutes, whichever is less, from the currently NRC approved or updated ETE, FENOC 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

2-3 DBNPS Post-Shutdown Emergency Plan Revision TBD FENOC determines the criteria for updating the ETE have been met and at least 180 days before 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 5O-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 lO-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 l0-mileEPZ 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 S0-mile radius. The principal concern in the 50-mileEPZ, 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 1O-mile and 50-mile EPZs. 2.4 RegulatoryRequirements 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 Post-Shutdown Emergency Plan Revision TBD 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. l, Criteria for Preparation and Evaluation of Radiological Emerqenc), Response Plans and Preparedness in Support of Nuclear Power Plants and in NEI 99-01. Methodology for Development of Emergency Action Levels. Revision 6. 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 Post-Shutdown 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 ofan emergency, both onsite and offsite.

f. To control onsite and offsite surveillance activities.

0

b. To establish procedures to identiff and classifu 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 EmergencyPlanlnterrelationships 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 Post-Shutdown Emergency Plan Revision TBD 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., AREVA NP, Bechtel, etc.). 2.7 Emergency Plan Procedures. Station Procedures and Fleet Business Practice Detailed Emergency Plan Procedures direct the implementation of this Post-Shutdown Emergency Plan. Detailed Station procedures prescribe appropriate courses of action necessary to place the facility 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 Post-Shutdown Emergency Plan Revision TBD 2.8 ParticipatingGovernmentalAgencies 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 Countv Radiological Emergency Response Plan 2.8.3 Lucas County, The Lucas Countv Radiological Emergenc), Response Plan 2.8.4 Erie County, Radiological Emergency Response Procedures Document 2.8.5 Sandusky Count5r, 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 Post-Shutdown 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 Post-Shutdown Emergency Plan Revision TBD Table2-l FUNCTIONAL INTERRELATIONSHIPS OF RESPONSE ORGANIZATIONS F F o E. o-d o CL F o- c= F F t E t t) o- o o (L o o- (9 o- (/, = (L l o- o- = G. a = a tlrJ J

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SFP 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 Emergency Operations Facility Warning R A A Control Room Notification & Communication A R A A Control Room/EOF Public lnformation R A A Joint lnformation 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 Radiolog ical Exposure Control A R A Emergency Operations Facility LEGEND: R=Task Responsibility A=Task Assistance LOCAL STATE FEDERAL ENGINEERING SUPPORT Ottawa County EMA Ohio EMA US NRC Region lll Areva, NP Ottawa County Sheriff Ohio Department of US DOE Bechtel Power Corp. Ottawa County Health Department Transportation US EPA Oftawa County Engineer Ohio EPA FEMA OTHER SUPPORT Carroll Township Fire & EMS Ohio State Highway Patrol US Coast Guard American Nuclear lnsurers 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 Post-Shutdown Emergency Plan Revision TBD Figure 2-l DBNPS General Site Location l'{b 4ad DAVI938SS8 rcRT BOWLING GREEN NORWALT

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2-tt DBNPS Post-Shutdown Emergency Plan Revision TBD Figare 2-4 DBNPS SO-Mile Emergency Planning Zone I.I\KE ST CI.AIR a 1 WINDSOR ANNARBOR . N 50 20 ERIE MICHIGAN OHIO STA PORT LORAIN

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3-l DBNPS Post-Shutdown Emergency Plan Revision TBD 3.0

SUMMARY

OF THE POST-SHUTDOWN EMERGENCY PLAN The DBNPS Post-Shutdown 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-I and other documents. The Post-Shutdown Emergency Plan will be put into effect whenever a radiological emergency or other potentially hazardous situation is identified. The details of the Post-Shutdown Emergency Plan Procedures are not included herein, but a description ofthe scope ofthe 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 Post-Shutdown 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 propefty and safety ofthe general public. 3.1 Post-Shutdown Emergency Plan Steps In general, the Post-Shutdown 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 EmergencyOrganizations 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 ifthe situation dictates. An individual with the authority and responsibility to initiate any emergency actions under the provisions of this Post-Shutdown 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 Director upon initial classification of an emergency. If the Shift Manager cannot assume these duties, authority is delegated to another qualified member of the on-shift staff. The Emergency Plant Manager or Emergency Assistant Plant Manager may assume the Emergency Director position upon arrival in the Control Room or TSC.

3-2 DBNPS Post-Shutdown Emergency Plan Revision TBD The designated Emergency Director, upon arrival in the Emergency Operations Facility (EOF) or Technical Support Center (TSC), will assume this authority. The on-shift crew is responsible for implementing emergency procedures in accordance with assigned response functions. Emergency response functions are also assigned to off-shift facility 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 Emergenclz 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.

J-J DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Countv 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 Sandushv Countv 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 (5O-mile EPZ). The Ohio EMA will notifu 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 Post-Shutdown Emergency Plan Revision TBD 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 EmergencyCategories Emergencies are grouped into four categories. From least to most severe they are: 3.3.1 UNUSUAL EVENT J ).2 ALERT J.J.J 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.

3-5 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 3-I EMERGENCY CATEGORIES AND THE DEGREE OF PARTICIPATION BY VARIOUS GROUPS Participation Necessity Bv Various Oreanizations for Emergency Protective Actions Mitigative DBNPS Offsite Category Onsite I Offsite Actionsr 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 tAction might include local fire support, ambulance service, medical assistance, or radiological assessment. 'zNotification Status: Organization informed of situation onsite 3Standby Status: Organization staffs preplanned centers, establishes communications, and assembles emergency teams, as required.

4-l DBNPS Post-Shutdown Emergency Plan Revision TBD 4,0 EMERGENCYCONDITIONS 4.1 Emergency Classification Levels (ECLs) The Davis-Besse Nuclear Power Station Post-Shutdown 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 identifring abnormal conditions and then comparing them to INITIATING CONDITIONS (ICs) through EMERGENCY ACTION LEVELS (EAL) and threshold values as discussed below. When multiple EALs are met, event declaration is based in the highest ECL reached. Post-Shutdown 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 atea. 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 LTNUSUAL 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 Post-Shutdown Emergency Plan Revision TBD 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 Post-Shutdown Emergency Plan. 4.2 EMERGENCY CLASSIFICATION The Davis-Besse Nuclear Power Station maintains the capability to assess, classiff, and declare an emergency condition within 15 minutes of the availability of indications that an EAL has been exceeded. The 1S-minute criterion commences when facility instrumentation, facility alarms, computer displays, or incoming verbal reports that correspond to an EAL first become available to any facility personnel. 4.3 INITIATING CONDITION 0Cs) The TNITIATING CONDITION (IC) and EMERGENCY ACTION LEVELS (EALs) with their related basis information are located in Appendix E of the Post-Shutdown Emergency Plan. The ICs provide a general description ofemergency 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 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

4-3 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Appendix E, DBRM-EMER-1500 A, Davis-Besse Emergency Action Levels Basis Document. 4.4 EMERGENCY ACTION LEVELS (EALs) EMERGENCY ACTION LEVELS (EALs) are predetermined, site specific, observable conditions within the ICs that place the state of the facility in a given ECL (Reference Post-Shutdown Emergency Plan, Appendix E). EALs are individually identified by the IC identification code followed by the EAL number, such as RGl.l for major effluent release or HU3.1 for tornado. 4.4.1 Deleted 4.4.2 Deleted For EALs that contain time imbedded criterion, the Emergency Director 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 Post-Shutdown Emergency Plan Revision TBD 4.4.3 Deleted 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 Director 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 Director, 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 LINUSUAL EVENTS, ALERTS, and certain SITE AREA EMERGENCIES causing no long term facility 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 facility conditions. Recovery phase is discussed in Section 9.2. 4.4.6 Classifuing 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 facility damage occurred while the mitigative actions were being taken. In some situations, this can be readily determined, in other situations, further analyses may be necessary. Classifu 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 classi$ing 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 facility, declaration requirements should not be considered to be met when the conditions are a part of the designed facility response, or result from appropriate operator actions. There may be cases in which a facility 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.

4-5 DBNPS Post-Shutdown Emergency Plan Revision TBD Reporting requirements of 10 CFR 50.72 are applicable and the guidance ofNUREG-l022,Event Reporting Guidelines, 10 CFR 50.72 and 50.73, should be applied.

5-l DBNPS Post-Shutdown Emergency Plan Revision TBD 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES In planning for emergencies the availability of the normally present on shift 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. These individuals will be capable of: (l) determining that an emergency exists, (2) providing initial classification and assessment, (3) promptly notifring 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 a SITE AREA EMERGENCY or a GENERAL EMERGENCY, this will result in the mobilization of all personnel resources of the Company, under the direction of a Senior Company Officer. This section of the Post-Shutdown 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) 5.8 SupportingEmergencyOrganizations 5.1 DBNPS Organization Spent fuel storage and engineering activities at DBNPS are under the control of the - General Plant Manager. DBNPS has engineering service contracts with 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 Facility Management and Administrative Organization The General Plant Manager directs and supervises all administrative, technical and maintenance activities in connection with the continuous, efficient and safe storage of spent fuel at the DBNPS. To support the General Plant Manager, an administrative organization has been established. Responsibilities have been assigned for the various aspects ofstation activities.

5-2 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Nl8.1, and includes both management and operations personnel. Figure 5-1, Onshift Emergency Organization, shows the functional levels. Other continuous duty, 24 hours-per-day organizations include Operations, Radiation Protection and Security. Maintenance personnel and the various Engineering organizations are onsite during normal work hours, Monday through Friday, excluding holidays. 5.1.3 Normal Facility Shift Staffing The facility's operating staff meets or exceeds the requirements of Technical Specification5.2.2. Table 5-1 MANPOWE& LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCTES, A. ONSHIFT MINIMUM STAFFING REQUIREMENTS describes the minimum on shift staffrng utilized to support the Post-Shutdown Emergency Plan. In addition, the facility is continuously staffed with a minimum shift complement consisting of the following: I Radiation Protection Technician 5 Fire Brigade Members (may have other assignments)

              +       Nuclear Security Force
                       +

safeguards information An established duty roster system provides access to facility management 24 hours aday. Table 5-1 specifies minimum shift requirements as prescribed by NUREG-0654, Table B-1. The Shift Manager directs the onshift personnel and verifies that their work is performed according to approved procedures. Ultimate authority for directing all phases of SFP operations always lies with the Shift Manager. The Shift Manager becomes the Emergency Director upon classification of an emergency at DBNPS. Non-Certified Operators, who are assigned to each shift, assist the Shift Manager by following his directives in controlling station equipment. During an emergency, the Non-Certified Operators may also function as emergency maintenance personnel or to assist fire brigade team members. An appropriately qualified Non-Certified Operator could assume the role of Shift Manager, including Emergency Director duties, should the Shift Manager become incapacitated.

5-3 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Post-Shutdown Emergency Plan Revision TBD 5.2 DBNPS Emergency Management ln the event of a declared ALERT or higher level emergency, the Onsite and Near Site Emergency Response Organization (ERO) shall be activated. The individuals responsible for managing the emergency are the Emergency Director, Emergency Offsite Manager, Emergency Plant Manager and the Company Spokesperson. 5.2.1 EmergencyDirector

a. The Emergency Director is the senior individual in the onsite ERO responsible for the coordination of the overall response to any emergency at the DBNPS. During such an emergency, the Emergency Director will coordinate and direct the emergency response from the Control Room, or the Emergency Operations Facility (EOF).

The following are non-delegable responsibilities of the Emergency Director:

1. Emergency Classification

2. Offsite Protective Action Recommendation a

J. Compliance with station procedures

4. Safety and well being of station personnel

5. Ordering a station general evacuation Responsibilities that the Emergency Director may delegate to the Emergency Plant Manager only are:

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

2. Onsite administration of Potassium Iodide (KI).

b. Reporting directly to the Emergency Director are:

1. Emergency Offsite Manager

2. Emergency Plant Manager J. Company Spokesperson

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

I Emergency Plant Manager 2 Emergency Assistant Plant Manager J Shift Manager 4 Another qualified on-shift individual 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

5-5 DBNPS Post-Shutdown Emergency Plan Revision TBD the Emergency Director, the Shift Manager may be relieved by the Emergency Assistant Plant Manager upon arrival in the Control Room or TSC. 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.

5.2.3 Emergency Plant Manager The Emergency Plant Manager is the senior individual responsible for the coordination and conduct of all activities associated with storage of spent fuel in the SFP, facility assessment, emergency classification associated with facility parameters, and onsite actions taken to mitigate the emergency situation. The Emergency Plant Manager reports to and advises the Emergency Director on facility 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.

5-6 DBNPS Post-Shutdown Emergency Plan Revision TBD 5.2.4 Company Spokesperson The Company Spokesperson is responsible for the overall operation of the Joint Information Center (JIC), conferring with the Emergency Director concerning facility stafus, 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 IIC during an emergency 5.2.5 Deleted 5.3 Onshift Emergency Response Organization Onshift Emergency Response Organization personnel are adequately trained to recognize, classifu, notifu, 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 Director The Shift Manager supervises the following activities:

a. The timely assessment of facility 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.

o b' Authorization of emergency radiation doses.

5-7 DBNPS Post-Shutdown Emergency Plan Revision TBD 5.3.2 Deleted 5.3.3 Deleted 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 Emergency Security Manager and interfaces with the OSC Manager and the OSC RP Coordinator. 5.3.5 Deleted

5-8 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 General Plant Manager. However, the Emergency Response Manager 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 staffing to satisfu 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 SFP during both normal and emergency conditions.

b. Technical Support Center (TSC)

TSC staffwill assess facility conditions, and provide management and technical assistance to the Control Room, as required, to mitigate the effects of the emergency event. The TSC staff will analyze and track parameters relating to the technical EALs, and will advise the Emergency Director of the need to reclassiff 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.

5-9 DBNPS Post-Shutdown Emergency Plan Revision TBD 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. 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 safe storage of spent fuel in the SFP. 5.4.3 Control Room In the Control Room, the Onsite Emergency Response Organization is the same as the Onshift Emergency Response Organization. 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 these facilities are directed by the Emergency Plant Manager. The following individuals report directly to the Emergency Plant Manager:

a. Emergency Assistant Plant Manager The Emergency Assistant Plant Manager is responsible for coordination and interface between the TSC emergency organization and the facility.

The Emergency Assistant Plant Manager advises the Emergency Plant Manager on facility status and trends, and their potential impact on protective action recommendations and emergency classifi cation. The Emergency Assistant Plant Manager interfaces with the Emergency Plant Manager, TSC Engineering Manager, Emergency Radiation Protection Manager, and the OSC Manager. Reporting to the Emergency Assistant Plant Manager is the Shift Manager and the Operations staff in the Control Room.

5- l0 DBNPS Post-Shutdown Emergency Plan Revision TBD

b. Emergency Radiation Protection Manager The Emergency Radiation Protection Manager is located in the TSC and is responsible for ensuring radiological assessment and surveys are conducted within the Protected Area. The Emergency Radiation Protection Manager coordinates facility protective action and health physics support for emergency activities, and interprets data to provide health physics and chemistry input to engineering assessments. The Emergency Radiation Protection Manager interfaces with the Dose Assessment Coordinator to provide data on facility radiological status and trends. In addition, the Emergency Radiation Protection Manager provides recommendations to the Emergency Plant Manager for emergency personnel doses, and the issuance ofPotassium Iodide to facility personnel.

The Emergency Radiation Protection Manager interfaces with the TSC Engineering Manager, the Emergency Security Manager, the OSC Manager, the OSC RP Coordinator, the Dose Assessment Coordinator and staff. c Technical Support Center (TSC) Engineering Manager The TSC Engineering Manager is responsible for performing an engineering assessment of facility conditions and/or actions needed to mitigate damage to the facility, continuously evaluate the need for engineering resources, and the coordination and supervision ofTSC engineering activities associated with development of emergency procedures to terminate or mitigate the emergency situation. The TSC Engineering Manager 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 Manager advises the Emergency Plant Manager on information pertinent to emergency classification, from the technical standpoint. The TSC Engineering Manager interfaces with the Emergency Assistant Plant Manager, OSC Manager and the Emergency Radiation Protection Manager. Other augmented, qualified engineering resources that may be requested report to the TSC Engineering Manager.

d. Emergency Security Manager The Emergency Security Manager 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.

5-l I DBNPS Post-Shutdown Emergency Plan Revision TBD The Emergency Security Manager reports to the Emergency Plant Manager and interfaces with the Emergency Radiation Protection Manager, and the OSC Manager.

e. 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 Manager The OSC Manager is responsible for the supervision of OSC personnel and 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:

I Emergency Repair 2 Search and Rescue J First Aid 4 Fire Brigade The OSC Manager reports to and interfaces directly with the Emergency Plant Manager and interfaces with the Emergency Assistant Plant Manager and the Emergency Radiation Protection Manager. The OSC Radiation Protection Coordinator reports to the OSC Manager.

5-12 DBNPS Post-Shutdown Emergency Plan Revision TBD

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

The OSC Radiation Protection Coordinator reports to the OSC Manager, and informs and is advised by the Emergency RP Manager. Reporting to the OSC Radiation Protection Coordinator are all RP testers not specifically assigned other responsibilities within the emergency organization.

c. 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.

5-13 DBNPS Post-Shutdown Emergency Plan Revision TBD

d. 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:

l. Emergency Repair

2. Search and Rescue J. First Aid

4. Fire Brigade Members of the OSC Personnel Pool report to the OSC Manager

5-14 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 General Plant Manager. However, the Emergency Response Manager 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 staffing to satis[, 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.

l. 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)

5- l5 DBNPS Post-Shutdown Emergency Plan Revision TBD In the event that the station is not accessible, OSC personnel will muster at the Lindsey Emergency Response Facility and standby to support the facility miti gation strategy. 5.5.2 Emergency Operations Facility (EOF) Organization Under the direction of the Emergency Offsite Manager, the following positions staff the EOF.

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

The Dose Assessment Coordinator interfaces with the Emergency RP Manager. The following individuals report directly to the Dose Assessment Coordinator:

1. Dose Assessment Staff The Dose Assessment Staff is responsible for evaluating facility and meteorological parameters associated with a potential or ongoing radiological release. 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 Assessment Staff interfaces with the RMT Coordinator and Rad Data Technician.

5-16 DBNPS Post-Shutdown Emergency Plan Revision TBD

2. Radiation Monitoring Team (RMT) Coordinator The RMT Coordinator is responsible for coordinating the activities of the RMTs 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 RMT Coordinator interfaces with the RTL Coordinator and the Dose Assessment Staff. Reporting to the RMT 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.

4. Radiation Monitoring Team (RMT)

Each Radiation Monitoring Team is comprised of two individuals who have been trained in radiological and environmental sampling techniques. The RMT members are responsible for taking air, water and soil samples, performing radiation surveys, and using associated survey equipment.

b. 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.

5-17 DBNPS Post-Shutdown Emergency Plan Revision TBD The Emergency Planning Advisor is responsible for the procurement of personnel and equipment. The EOF Communications Staff report to the Emergency Planning Advisor. 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), and the Nuclear Regulatory commission (NRC). A member of the EOF communications staff will be present at meetings between the ERO and the NRC. The EOF Communications staff may be augmented by additional personnel to assist in communications, Nuclear Network transmissions, and operations of support equipment.

c. 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) The Emergency Public Information staff is activated by call tree notification, and operates the Joint Information Center (JIC). Coordination of the JIC is the responsibility of the JIC Manager, who reports to the Company Spokesperson. 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 FirstEnerry facility. The Senior ERO Position member oversees the operation of the CAC and ensures that CAC activities are caried out in a manner that supports the requests made by the Emergency Director.

5- l8 DBNPS Post-Shutdown Emergency Plan Revision TBD 5.8 SupportingEmergencyOrganizations 5.8.1 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. Sample 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:

t. H. B. Magruder Hospital

2. Mercy St. Charles Hospital a

J. 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. 5.8.2 Medical Emergency Response Organization

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

l. 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

l. General Plant Manager:

5-19 DBNPS Post-Shutdown Emergency Plan Revision TBD The General Plant Manager is notified in all cases of serious personnel injury or illness.

2. First Aid Teams:

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) InjurieslnvolvingRadiologicalComplications: l) 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 patient's 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. RadiationProtectionPersonnel:

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 person's 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.

5-20 DBNPS Post-Shutdown Emergency Plan Revision TBD d) Shall provide the attending physicians with prompt evaluations of the internal and,/or external doses incurred by injured personnel. The services ofthe radiological emergency assistance provider are available for assistance in this matter.

4. Davis-Besse Security:

Shall notifr 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. RadiologicalEmergencyAssistanceProvider:

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

5-21 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 submiffed. 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. 5.8.3 Government Agency Support

a. Agreements with Government Agencies 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 facility, 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 0 Ohio Department of Transportation g) Ohio Emergency Management Agency (OEMA) h) Ohio Environmental Protection Agency

2. The Post-Shutdown Emergency Plan for DBNPS, and the emergency plans for the State of Ohio, Ottawa County and Lucas County, have been formulated to provide timely notification and close coordination with these agencies.

J 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

5-22 DBNPS Post-Shutdown Emergency Plan Revision TBD Operations Plan, the Ottawa and Lucas County Radiological Emergency Response Plans, and existing leffers 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 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 Sheriffs Office or the Ottawa County Emergency Management Agency (OCEMA) d) Lucas County Sheriffs Office or the Lucas County Emergency Management Agency (LCEMA) e) Ohio Emergency Management Agency or Ohio Highway Patrol 0 NRC, Emergency Incident Response Center 2 In the event of personnel injury/illness, which require transportation to an offsite medical facility, the Ottawa County Sheriffs Office will be notified so that local authorities may prepare to answer public/media inquiries. J. 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 Director will ensure that the Ottawa and Lucas County Sheriffs 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 notifuing the NRC. In the event that the ENS is unavailable, the NRC commercial number will be used. If

5-23 DBNPS Post-Shutdown Emergency Plan Revision TBD radiological concerns arise, the NRC Health Physics Network should be utilized. c Local Agencies

l. Ottawa County Sheriffs Office The Ottawa County Sheriffs Office is experienced in providing area control, communications assistance, and direct handling of the local population; including evacuation, should it become necessary. The Sheriffs Office provides 24-hour radio communication coverage with the Central Alarm Station at DBNPS. Until the OCEMA is activated, the Ottawa County Sheriffs Office is the lead Ottawa County agency contacted in the event of an emergency at DBNPS.

2. Lucas County Sheriffs Office The Lucas County Sheriffs 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 Sheriffs Office is the lead Lucas County agency contacted in the event of an emergency at the site.

J 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, fre, 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:

l. 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.

s-24 DBNPS Post-Shutdown Emergency Plan Revision TBD c) Coordinate preparation ofannexes by other State agencies having response capability I 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. s) Coordinate with adjacent states in matters pertaining to radiological emergency planning. 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. i) Make provisions for the alerting of boaters on Lake Erie inside the lO-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 l0 mileEPZ 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.

5-25 DBNPS Post-Shutdown Emergency Plan Revision TBD 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.

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. 0 Develop plans for: l) 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).

5-26 DBNPS Post-Shutdown Emergency Plan Revision TBD

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. 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 propefty (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 Engineer's 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 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 Offrce, 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)

5-27 DBNPS Post-Shutdown Emergency Plan Revision TBD Region V, USEPA, Chicago, will provide support to the DOE, Chicago Operations Office, upon request. This support consists of qualified radiation monitoring teams.

3. Nuclear Regulatory Commission, Region [II, Office of Inspection and Enforcement.

The Office of Inspection and Enforcement Region III, NRC, will dispatch personnel to the scene in the event ofan 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 notifuing boaters on Lake Erie. 5.8.4 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. Davis-Besse's Insurance Carriers

1. There are three occasions that require interfacing with the lnsurance c,uTlers:

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 lmplementing Procedures. J In the event ofan 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

5-28 DBNPS Post-Shutdown Emergency Plan Revision TBD incident at an AM 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 ofthe 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.

6. Nuclear Electric Insurance Limited is the Station's property damage carrier and is notified of situations requiring their attention by appropriate Station procedures.

b. Architect/Engineer Support The ArchitecV Engineer (A/E) for construction of the Davis-Besse facility was the Bechtel Power Corporation. This firm can be called on during emergency situations to provide the technical analysis and engineering support necessary to mitigate abnormal facility conditions.

c. 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.

5-29 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 5-I MANPOWE& LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Page I of2 A. ONSHIFT MINIMUM STAFFING REQUIREMENTS BO E O6 E Functional Area Major Tasks Emergency Positions

                                                                                                        ?"cn E=
                                                                                                        !E 4rA Shift Manager / Certified Fuel Plant Operations and Assessment of Handler (CFH)                           I Control Room Staff Operational Aspects Non-Certifi ed Operator (NCO)           2

2. Emergency Direction and Command and Control Shift Manager 1(a)

Control (a) Licensee CAS Operator

3. Notification & 1 LocaU State NCO or above I (a)

Communication Federal NCO or above 1 (a) Dose Assessment NCO or above 1 (a) In-plant Surveys RP Technician I

4. Radiological Assessment Onsite Surveys RP Technician lG)

Chemistry RP Technician I (a) Technical Support - OPs NCO or above I (a)

5. Plant System Engineering, Repair, and Mechanical Repair I (a)

Mitigative Actions Repair and Mitigative Actions Electrical Repair I (a) I&C Repair I (a)

6. In-Plant PAs Radiation Protection RP Technician 1 (a)

Fire Brigade Captain (NCO) (a)

7. Fire Fighting I

Fire Brigade Member 4

8. l't Aid and Rescue NCO 1 (a)

Security Shift Supervisor

9. Site Access Control and 1

Security & Accountability CAS Operator I Accountability Security Personnel (b) TOTAL: 10 Notes: Personnel assigned to the shift in excess of the minimum staffrng 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 Post-shutdown On-Shift Staffing Analysis Report, documents the minimum shift's ability to implement the emergency plan. Operations personnel are qualified on survey instruments. (a) May be filled by someone filling another position having functional qualifications. (b) Per DBNPS Physical Security Plan.

5-30 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 5-I MANPOWER, LOCATION, AND RESPONSE CONSIDERATTONS 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 )3 Alerted Emergency Assistant Plant Manager (1 )3 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 (1) 30 minutes Elecirical Maintenance (1) Add Total Off Hours: RP Technician (1) (2) 60 minutes RP Technician (1) (3) 1-2 hours TECHNICAL SUPPORT CENTER TECHNICAL SUPPORT CENTER As Required: TSC Engineering Manager (1) Alerted TSC Engineering Manager (1) Normal Hours: 30 minutes Off Hours: 60 minutes TSC l&C Engineer TSC Electrical Engineer Call in as 1-2 hours necessary TSC Mechanical Engineer 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: 60 minutes RMTs (3) 30-60 minutes Emergency Director (1)

                                                                                                                                          'l-2 hours State/County Communicator                                        (1)

NOTES: 1. All time requirements are based on optimum response conditions.

2. Figure 5-2, Emergency Response Organization, depicts functional levels beyond these augmented staffrng requirements.

3. The Emergency Assistant Plant Manager may respond to the TSC.

5-31 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-I ONSHIFT EMERGENCY ORGANIZATION Page 1 of 1 Shift Manager Radiation Protectim Operations Security Personnel Shift Supervisor Nuclear Security For@

5-32 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 1 of 10 Emergency Director Emergency Plant Emergency Offsite Company Spokesperson Manager Manager see figure 5-2page2 see figure 5-2 page 8 see figure 5-2 page 1 0 Responsibilities: Responsibilities: Responsibilities: -Plant Operations -Offsite Communications -Communications with the -Engineering - Dose Assessment News Media Assessment -Radiation Protection -Repair Activities -Station Security

s-33 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 2 of 10 Emergency PlantManager Emergency Assistant TSC Emergency 0sc Emergency Plant Man4er Engineering Manager RP Manager Manager Security Manager see figure $2 page 3 see figure $2 page 4 see figure 5-2 page 5 see figure $2 page 6 see figure 5-2 page 7 Responsibilities Responsibilities: ReEonsibilities: ReEonsibilities: Reponsibililies: - Plant 0perations - Engineaing Asessment - Radiological Eval ualim - Emeqency Repais - Acces Contrd

                                                          - Chemistry Evaluation    - &arch & Rescue       - Station Sority
                                                                                    - Danage Cmtrd

5-34 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 3 of 10 Emergency Assistant Plant Manager ControlRoun Communicator shift Manager Operations Personnel

s-35 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5.2 Emergency Response Organization Page 4 of 10 TSC Engineering Manager

5-36 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 5 of 10 Emergency RP Manager OSC RP Coordinator RP Chemistry Technicans Technicans

5-37 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 6 of 10 OSC Manager OSC RP OSC Pod Personnel Coordinator RP &Chemislry Personnel

5-38 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 7 of 10 Emergency Security Manager Security 0cA Shift Supervisor Security Supervisor Nuclea Security Force

5-39 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 8 of 10 Emergency 0ffsite Manager Dose Assessment Emergency Technical Liaison - EOF Coordinator Planning Communicata Advisor Technical Liaison - see figure $2 page 9 State / County State of Ohio Communicator Technical Liaison - Ottaua County Technical Liaison - Lucas County

5-40 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 9 of 10 Dose Assessment Coordinator RTL RMT Dose Assessors Coordinator Coordinator (1) DBAB Field RMTs RMTs

5-41 DBNPS Post-Shutdown Emergency Plan Revision TBD FIGURE 5-2 Emergency Response Organization Page 10 of 10 Company Spokesperson Jrc Manager Searity Technical PuUic lrquiry Briefer Hotine Opeatu (1) Media Assistant (2)

6-l DBNPS Post-Shutdown Emergency Plan Revision TBD 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 classifi cation.

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 Director, will implement this plan by initially classifuing 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. o 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 l5 minutes. Any subsequent changes to PARs continue to be provided to the agencies within l5 minutes. o Nuclear Regulatory Commission (NRC) The NRC is notified immediately after notification of the appropriate state and local agencies and not later than one (l) hour after the time of initial event declaration, escalation to a higher classification level, emergency termination or entry into recovery.

6-2 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 commercial telephone service. An open, continuous communication line is maintained with the NRC Operations Center upon request. An NRC Event Notification Worksheet (Form 361) may be utilized to assist in communicating event and facility 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. a Support Organizations Medical, rescue, and firefighting support services are notified for assistance as the situation dictates. The American Nuclear lnsurers (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 verift 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 .l Shift Manager/Control Room Operations

a. Should emergency conditions arise, it is expected that the Non-Certified Operator(s) and/or the Shift Manager will be made aware of the situation by alarms, instrument readings, reports, etc. The Non-Certified 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., systems and SFP status, radiological conditions, etc.) in the following manner:

1 Determine the immediate actions to be taken to ensure the safe and proper operation of the SFP. 2 If the situation requires implementation of the DBNPS Post-Shutdown Emergency Plan, the Emergency Director will: a) Classiff the emergency. Classification of emergencies is a non-delegable responsibility of the Emergency Director.

6-3 DBNPS Post-Shutdown Emergency Plan Revision TBD 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) Notiff the following personnel and organizations of the emergency conditions: l) Nuclear Security Supervision.

2) Station Management.

3) Ottawa County Sheriff/EMA (within l5 minutes).

4) Lucas County Sheriff/EMA (within 15 minutes).

s) Ohio State Highway Patrol/EMA (within l5 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 Director. ) 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 SFP. 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 Post-Shutdown Emergency Plan Revision TBD 6.1.2 EmergencyDirector The designated Emergency Director, upon being informed that an emergency exists and has been declared by the Emergency Director on-shift will:

a. Review information, data, and methods used by the on-shift Emergency Director (Shift Manager) in making the emergency classification. The Emergency Director may NOT delegate the responsibility of classifting 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 Director. 2 For an ALERT, all of the ERO will be activated. Key individuals in the CAC will be alerted. J 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.

e. Ensure 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.

f. Ensure 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 notifr 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 notifr 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 Post-Shutdown Emergency Plan Revision TBD 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 hours 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 hours. 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 Post-Shutdown Emergency Plan Revision TBD 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 facility 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 facility instrumentation.

b. If possible, the dispatching of shift personnel to the identified problem area to confirm and visually assess the problem.

c. The dispatching of personnel to monitor for possible releases, and to confirm the correct classifi cation.

d. If a radiological incident is occurring, surveillance of the facility 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 Director. Emergency Plan Procedures are provided to allow a rapid, consistent projection ofdose.

e If a security event is in progress, then the emergency organization will immediately implement specific procedures for security events or threats.

6-7 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 SFP status,)

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 RMTs 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 Post-Shutdown Emergency Plan Revision TBD 6.3 Mitigative Actions Detailed operating procedures are available for use during emergencies, as well as during normal operations. Specific procedures are provided to assist the operators in placing the facility in a safe condition, and taking necessary supplemental mitigative actions. In addition, Operations personnel are trained in the operation of the SFP systems and their associated procedures, and are therefore capable of taking appropriate mitigative actions based on their training, knowledge, and experience Selected DBNPS Staffpersonnel, 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 Director 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 Director. 6.4 Protective Actions Protective actions are emergency measures taken during or after an emergency situation to minimize or eliminate thehazard 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 Facility 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. Facility 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 assembly areas. Personnel will be trained as to the location of assembly areas and the suggested routes to each. Visitors will assemble with their escorts, or be escorted offsite. At the assembly areas, members of the emergency organization will conduct personnel assembly and evacuation (if required). Accountability within the protected area is coordinated by the OSC Manager and Security. The goal for completion of personnel accountability is 30 minutes. Results

6-9 DBNPS Post-Shutdown Emergency Plan Revision TBD are forwarded to the Emergency Director. 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 Director/Shift Manager, a personnelhazard exists. Nonessential personnel shall be evacuated from the site if a GENERAL EMERGENCY has been declared, or if at the discretion of the Emergency Director/Shift Manager, site evacuation is warranted for personnel safety reasons. Access control will be established by Security to prohibit the entry ofunauthorized personnel to the protected area. Personal vehicles will be used for site evacuation. Nonessential personnel may be evacuated to the designated offsite assembly area; the Lindsey Service Center, or other company facilities as appropriate. Personnel and vehicles will be monitored for contamination at the offsite assembly area, if necessary, prior to release.

b. Facility 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 as described below. At other site locations (i.e., Davis-Besse Training Center, Davis-Besse Administration Building and Annex, Warehouse), 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 landiwater based, as well as airborne attacks). Generally, these protective actions may include considerations for:

o Site evacuation via normal exits o Site evacuation via alternate means o Dispersal of Operations personnel, and essential ERO members

6-10 DBNPS Post-Shutdown Emergency Plan Revision TBD o Take Cover (sheltering in place for personnel onsite) 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: Responsibilrty for implementing actions to protect personnel in offsite areas rests with State and local officials, and is described in detail in The Ohio Radiological Emergenc), Preparedness Plan and the Ohio Emergency Operations Plan (under a separate cover), and is implemented in conjunction with The Ottawa Coun8 Radiological Emergency Response Plan, and The Lucas Countv 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 l, and its PAR logic diagram. The process includes consideration ofprecautionary protective actions, wind persistence, rapidly progressing release scenarios, hostile-action based events, and termination ofprotective 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 l0-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 Sheriffs 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-l I DBNPS Post-Shutdown Emergency Plan Revision TBD 6.4.3 Use of Onsite Protective Equipment and Supplies Table 6-l 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 Laboratory 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 EmergencyPersonnelExposure 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-92-001guidance for these emergency activities:

6-12 DBNPS Post-Shutdown Emergency Plan Revision TBD

a. Mitigative/protective actions Limit doses to the following when protecting valuable propertv and lower doses are not practicable:

I 10,000 mrem Total Effective Dose Equivalent (TEDE) 2 30,000 mrem Lens Dose Equivalent (LDE) J 100,000 mrem: a Total Organ Dose Equivalent (TODE) a 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:

I 25,000 mrem TEDE 2 75,000 mrem LDE J 250,000 mrem o Total Organ Dose Equivalent (TODE) a Shallow Dose Equivalent (SDE) to the skin of the whole body or to any extremity The Emergency Director 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 ofsuch 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 Director 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 Director or, when designated, the Emergency Plant Manager shall authorize the use of the thyroid blocking agent, i.e., potassium iodide (KI).

6-13 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Post-Shutdown Emergency Plan Revision TBD 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 MedicalTreatment 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- l5 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 6-I PAGs for the Early Phase of a Nuclear Incident PAG Protective Action (Proiected Dose) Comments Evacuation (or shelteringr) l-5 rem2 Evacuation (or for some situations, shelteringt) should normally be initiated at I rem. Administration of stable iodine 25 rem3 Requires approval of State medical officials tSheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration offactors 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. 'Committed dose equivalent to the thyroid from radioiodine. Guidance on Dose Limits for Workers Performing Emergency Services Dose Limitr Activity Condition (rem) 5 all l0 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

'Sum 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 Post-Shutdown Emergency Plan Revision TBD TABLE 6-2 RECOMMEIYDED PROTECTIVE ACTIONS Accident Phase Exposure Pathway Examples Of Actions To Be Recommended Emergency Phaset Inhalation of gases, radio- Evacuation, shelter, access control, (0 to 4 hours) iodine, or particulate respiratory protection, prophylaxis (thwoid 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 lngestion offruits and Wash all produce, or impound produce, PHASE, vegetables delay harvest until approved, substitute uncontaminated Ingestion of water Cut off contaminated supplies, substitute from other sources, filter, demineraliz,e (4 to 48 hours) Whole body exposure and Relocation, decontamination, access inhalation control LONG TERM Ingestion of food and water Decontamination, condemnation, or PHASE, 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. 'Emergency phase - Time period of major release and subsequent plume exposure 2lntermediate phase - Time period of moderate continuous release with plume exposure and contamination of environment. 3long Term Phase - Recovery period.

6-17 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 6-3 REPRESENTATIVE SHTELDING FACTORS FROM GAMMA CLOI]D SOT]RCE Shielding' Representative Range Structure or Location Factor Outside 1.0 Vehicles r.0 Wood-frame house2 0.9 (no basement) Basement of wood house 0.6 0.1to 0.73 Masonry House (no basement) 0.6 0.4 to 0.7t Basement of masonry house 0.4 0.1 to 0.5, Large office or industrial 0.2 0.1 to 0.3:,a building IThe ratio of the dose received inside the structure to the dose that would be received outside the structure. zA wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes. 3This range is mainly due to different wall materials and different geometries. oThe 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-l 8 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 6-4 SELECTED SHIELDING FACTORS FOR AIRBOR}I'E RADIOI\UCLIDE S 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 Post-Shutdown Emergency Plan Revision TBD TABLE 6-5 REPRESENTATTVE SHIELDING FACTORS FOR SI]RFACE DEPOSITED RADIOI\IUCLIDES Structure or Location Representativel Representative Shielding Factor Range 1 m above an infinite smooth surface 1.00 I m above ordinary ground 0.70 0.47-0.85 I m above center of50-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 0.4, 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 0.03-0.1s One story, less than 2 ft of basement, walls 0.05, 0.03-0.07 exposed Two stories, less than 2 ft of basement, walls exposed 0.03, 0.02-0.05 Three- or four-story structures, 5000 to 10,000 ft2 per floor First and second floors 0.0s, 0.01-0.08 Basement 0.01, 0.001-0.07 Multistory structures, >10,000 sq. ft. per floor: Upper floors Basement 0.01, 0.001-0.02 0.005, 0.001-0.015 tThe 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 Post-Shutdown Emergency Plan Revision TBD TABLE 6-6 Page I of2 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-131' Cs-1342 Cs-1372 Sr-90 Sr-89 Initial Activity Area Deposition (pCi/m2) 0.13 2.0 3.0 0.5 8.0 Forage Concentration3 (pCi/kg) 0.0s 0.8 1.3 0.18 3.0 Peak Milk Activity (pCi/l) 0.0r5 0.15 0.24 0.009 0.14 Total Intake (pCi) 0.09 4.0 7.0 0.2 2.6 'The cumulative intake of Iodine-133 via milk is about 2 percent of Iodine-l31 assuming equivalent deposition. 2lntake of Cesium via the meaVperson 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-l34 and Cesium-t37 are equally present, the response levels should be reduced by a factor of two. 'Fresh weight.

Reference:

Federal Radiation Council. Radiation Protection Guidance for Federal Agencies. Federal Register (May 22, I 965).

6-21 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 6.6 Page2 ofZ GUIDELINES FOR PROTECTION AGAINST INGESTION OT' 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 r-13 l Cs-1342 Cs-137 Sr-90 Sr-89 Infant3/Adult Infant4/Adult Infant4/Adult Infant4/Adult Infant4/Adult Initial Activity 1.3/18 20140 30/50 5.0120 80/1 600 Area Deposition @Cilm2) Forage 0.s17.0 8.0117 t3lt9 1.8/8.0 301700 Concentrations (pCi/kg) Peak Milk 0.01512.0 1.513.0 2.414.0 0.0910.4 1.4t30 Activity (pci/l) Total Intake 0.9110 40170 70180 2.0/7.0 261400 (pci) 'The cumulative intake of Iodine-l33 via milk is about 2 percent of Iodine-l3l assuming equivalent deposition. '?Intake of cesium via the meaVperson pathway for adults may exceed that of the milk pathway; therefore, such levels in milk should cause suryeillance and protective actions for meat as appropriate. If both Cesium-134 and Cesium-l37 are equally present, the response levels should be reduced by a factor of2. 3Newborn infant, includes fetus (pregnant woman) as critical segment of population for Iodine-l3l a"Infant" refers to child less than I year ofage sFresh weight.

Reference:

Federal Radiation Council. Radiation Protection Guidance for Federal Agencies. Federal Register (May 22,1965).

6-22 DBNPS Post-Shutdown Emergency Plan Revision TBD Figure 6-1 Page 1 of4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACTIONS ACTIONS EVENT or Provide for fire, law enforcenr or Emergency Response Organization of the medical assistance, UNUSUAL EVENT. as as needed summary to offsite authorities, or escalate to a higher classification if conditions warrant. until terminalion

6-23 DBNPS Post-Shutdown Emergency Plan Revision TBD Figure 6-1 Page2 of 4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSlTE ACTIONS ACTIONS ALERT Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medical as ALERT Activate EOCs and other response Assess and nd. centers as needed. Activate TSC EOF & JtC. Alert key emergency personnel to status Place RMTs on Alert Radiation Monitori Teams. Activate communication networks. Maintain ALERT status until the CAC termination, downgrade, or escalation of the classification Provide ic facil status u Provide meteorological conditions to offsite authorities. Make Senior Management and Technical personnel available to the County, State, and NRC for consultation. Assemble Protected Area nel Terminate with verbal summary to offsite authorities, or escalate to a higher classification if conditions warrant.

6-24 DBNPS Post-Shutdown Emergency Plan Revision TBD Figure 6-1 Page 3 of4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACT!ONS SITE AREA ACTIONS EMERGENCY Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medical assistance AS uested SITE AREA EMERGENCY Activate sirens and transmit an Assess and nd. EAS Activate OSC, TSC, EOF, JIC Activate the State & County EOCs, and CAC. and other centers. RMTs Alert personnel needed for evacuation of the blic to status. Activate communication networks. Dispatch key personnel and RMTs Make Senior Management and to locations Technical personnel available to the County, State, and NRC for Activate communication networks. consultation. Continuously assess data from D-B Provide ic faci status u 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 eme classification conditions

6-2s DBNPS Post-Shutdown Emergency Plan Revision TBD 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 EAS message. Activate OSC, TSC, EOF, JIC Activate the State & County EOCs, and CAC. and other response centers. RMTs. Recommend sheltering or evacuating within a 2 mile radius of the facilig, 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 personnel and RMTs. County, State, and NRC for consultation. Recommend placing milk animals within 2 miles on stored feed and Provide status u 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 Post-Shutdown Emergency Plan Revision TBD Figure 6-2 Page I of2 EMERGENCY NOTIFICATION UNUSUAL EVENT Davis-Besse Station Ottawa Lucas State of DBNPS Emergency Corporate US

6-27 DBNPS Post-Shutdown Emergency Plan Revision TBD Figure 6-2 Page2 ofZ EMERGENCY NOTIF'ICATION: ALERT, SITE AREA EMERGENCY, GENERAL EMERGENCY Davis-Besse Nuclear Power Station US DBNPS Emergency State of Oftawa 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 Post-Shutdown Emergency Plan Revision TBD Figure 6-3 OT'F'SITE EMERGENCY EVACUATION ROUTES 2 g2 E E 2< t s o @ e z 6 I 5 z eI f o z g 6 o z a o 2o II I

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7-l DBNPS Post-Shutdown Emergency Plan Revision TBD 7.0 EMERGENCY FACILITIES AND EOUIPMENT 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 identifring 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 activities. Other items are reserved for use only on an "as needed" basis. 7.1 DBNPS In-Plant Emersency Facilities 7.1.1 Control Room

a. The Control Room is the location from which the SFP systems are monitored. It contains the instrumentation, controls, and displays for:

I Electrical systems 2 Systems associated with the SFP J Accident monitoring systems. The on-shift staff is in accordance with TS 5.2.2. Control manipulations and the safe operation of the SFP are directed by the Shift Manager (qualified as a Certified Fuel Handler (CFH)) and are performed by Non-Certified Operators.

b. During abnormal conditions, the complexity of Station responsibilities increases and the Control Room transforms into an emergency response center. These responsibilities include the following:

I Diagnosing the abnormal conditions. 2 Performing mitigative actions. 5 Mitigation of abnormal conditions. 4 Management of SFP 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 SFP to a safe condition. 9 Recovering from the abnormal conditions. 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.

7-2 DBNPS Post-Shutdown Emergency Plan Revision TBD During emergencies, the Emergency Assistant Plant Manager may use 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 facility 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. 7.2 Davis-BesseAdministrationBuilding(DBAB)Facilities The DBAB contains the Emergency Response Facilities (ERFs) necessary to assist Control Room personnel in accident assessment and abnormal 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: I Help the Control Room staff determine the facility safety status. 2 Relieve the Control Room staff of peripheral duties and communications not directly related to SFP system manipulations.

   )        Prevent congestion in the Control Room.

4 Provide assistance from technical personnel who have comprehensive facility 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 facility data to the NRC for its analysis of 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 Post-Shutdown Emergency Plan Revision TBD 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 unintemrptible 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 facility 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 contained in the Emergency Plan Procedures. 7.2.2 Radiological Testing Laboratory GTL) 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 Post-Shutdown Emergency Plan Revision TBD The RTL is on the ground floor of the DBAB. 7 .2.3. 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. 7.2.4 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 Post-Shutdown Emergency Plan Revision TBD 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 unintemrptable 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). The EOF utilizes various communication systems to establish and maintain communications with State, Federal, and local officials, and mobile Radiation Monitoring Teams (RMTs). The EOF provides space for at least 22 people Activation and operation of the EOF is 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 operation 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 facility status and emergency response actions. JIC facilities include news briefing areas for electronic and print media representatives. JIC support is available for any facility emergency. However, facility activation is mandatory at (and above) the Alert

7-6 DBNPS Post-Shutdown Emergency Plan Revision TBD emergency classification level. The JIC is located at a FirstEnergy Corporation facility outside the l0-mile EPZ. 7.4.2 Corporate EmergencyFacilities 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 centralizedmanagement 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/facility. 7.5 Coun8 and State Emergenc), 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 l0-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 SherifPs Office. Davis-Besse dispatches a technical liaison to the EOC to help to aid offsite officials in understanding the event. 7.s.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 l0-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 Sheriff s 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 Post-Shutdown Emergency Plan Revision TBD A reliable communications system, utilizing the Fixed Monitor Station Network of the State Highway Patrol, ties all areas, and both the Offawa 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 six in/out bound offsite communications paths.

o 2 paths connect to the FirstEnergy company communications system. e 3 priority circuits travel to Toledo where then connect to the commercial telephone system. r I prioriW circuit connects directly into the local 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:

l. Voice over [P service from the Akron Ohio West Akron Campus

c. A public address system (Gai-tronics), which is totally separate from the telephone system, includes handset stations, loud speakers, and portable station jacks. [t provides five normal facility 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 Sheriffs dispatcher.

3. A channel used exclusively by Security.

7-8 DBNPS Post-Shutdown Emergency Plan Revision TBD 4 A channel used by the Maintenance Department for normal day-to-day transmissions. 5 A channel is used by Operations personnel for normal day-to-day transmissions.

e. Radiation Monitoring Teams communicate on a five-channel tmnked 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.

o b' A Computerized Automated Notification System (CANS) is available to facilitate the notification process. The system is composed of a minimum of 26 phone lines. 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 EmergencyCommunications Systems

a. The following phone systems are dedicated for emergency communications:

I The Davis-Besse 4-Way Phone including the State and County EOCs, the Ohio Highway Patrol Office, the Lucas County and Ottawa County Sheriffs dispatcher offices, the Emergency Operations Facility, and the Control Room.

2. A diverse network of commercial telephones, on unintemrptable power has been installed to provide:

a. NRC Emergency Notification System (ENS) telephone ("red phone").

b. NRC Health Physics Network (IfN) telephones.

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:

l. 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

7-9 DBNPS Post-Shutdown Emergency Plan Revision TBD

2. Radiation Management Bridge 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 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 Emergency Response Manager. 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 facility areas (i.e., station office building, personnel shop facility, radiologically controlled area, fuel handling area, outdoor areas, primary access facility, etc.)

7-10 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 l0-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-I, REV. 1. Local authorities activate the warning sirens from the Ottawa County Sheriffs 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 Sheriff s Dispatch Center as follows: o A three-minute audible test is performed at least once per year o A one-minute audible test is performed at least monthly r 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 l0-mileEPZ 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 Sheriffs 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 Sheriffs Offices have central dispatches, manned 24 hours 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-tt DBNPS Post-Shutdown Emergency Plan Revision TBD 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 facility. 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 facility 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 [I Part E; and The Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan. 7.9 AssessmentFacilities 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 ofan incident. 7.9.1 Radiation Monitoring System The onsite Radiation Monitoring System contributes to personnel radiological protection within the facility, 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 I1.4-1, Liquid Gas, and Airborne Radiation Monitors, and Table l2.l-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. Radiation monitors are powered from the essential instrument distribution panels.

The non-essential radiation monitors are powered from the unintemrptible instrument distribution panels.

d. 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.

7-12 DBNPS Post-Shutdown Emergency Plan Revision TBD

f. The modules are designed so that an alarm and/or indication is initiated when failure occurs anywhere in the channel.

7.9.2 Area Radiation Monitoring The Area Radiation Monitoring subsystem is comprised of area monitors located throughout the facility. Under normal operating conditions, the area monitors warn personnel of increasing radiation level, which may result in a radiation health hazard. Area monitors consist 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 ofthese channels is separate from the detector and is also housed in a weatherproof container. The Control Room readout modules are located in the radiation monitoring panel in the Control Room. 7.9.3 AtmosphericRadiationMonitoring 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 ProcessRadiationMonitoring 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-t3 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 facility 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 offloor area underthe 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 ofthe 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 l% inch hose, with an adjustabl e fog nozzle, and a separate 2%-inch hose connection for local fire department use. Fire extinguishers are provided throughout the building.

7-14 DBNPS Post-Shutdown Emergency Plan Revision TBD Hose reel units are provided in the turbine building. Each reel is provided with 50-75 feet of l% inch fire hose, and an adjustable fog and stream hose nozzle. Adjacent to each hose reel is a separate 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.

l. 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

7-15 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 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 0.0109 (5acceleration due to gravity). The recording system includes pre-event (i.e., pre-trigger) data in the event record. Recording continues without intemrption 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. In keeping with the purposes of the system, loss of site power will not prevent system operation. Backup power is supplied from 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 (AT) 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 and Display System (DADS). All meteorological data are recorded on strip chart recorders. 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

7-16 DBNPS Post-Shutdown Emergency Plan Revision TBD one multipoint strip chart recorder; each parameter is recorded on an individual channel. The data recording and 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 SFP systems. USAR Table 7.5-1 provides a listing and a description of Control Room instrumentation that would be used in performing continued assessment of facility 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 SFP operations. This equipment can also be utilized in the analysis of abnormal events 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 GTL) 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 station vent sampling, procedure guidance exists for sampling using either the normal or accident range station vent monitors. Provisions are included to replace and quantifu radioactive particulate and iodine sampling media. Also if RE 4598 series Chann el I , 2 or 3 is off scale, a portable survey instrument on the sample line can be used and dose rate is then converted to pCi/cc.

7.9.11 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,

7-17 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 has 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. Radiation Monitoring Teams (RMTs), dispatched at an ALERT or higher, will conduct emergency field monitoring of radiation and airborne activity levels throughout theEPZ, under direction from the Dose Assessment Center, in the EOF. Monitoring results will be used to verifu 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 Post-Shutdown 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, safet5r, security, and damage control of the facility. 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 (FIEPA), 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-purifuing respirators are available in the Radiologically 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

7-18 DBNPS Post-Shutdown Emergency Plan Revision TBD kits placed throughout the facility. 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 permanently shutdown and defueled 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-t9 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 7.1 Page I of2 Radiation Monitorins Instruments and Equipment A. Portable Radiation Survey Instruments Type Range Detector Quantity Location High Range 0-1000 5 RTL Survey mrad/hr-IO3 rad/hr GM J RP Area Instruments Ion 0-50 R/hr Chamber 6 RTL Low Range Ion Survey 0-5 rem/lr Chamber 2 RP Area Instrument 0-5 x 105 cpm GM 4 RTL Alpha Survey Meter 0-5 x 105 cpm Scintillator I RP Area Neutron 0-5000 mrem/hr BF: 2 RP Area B. Portable Air Sampling Equipment Type Quantity Location Environmental Offsite Air Sample 10 Survey Stations Low 12 volt D.C. 4 RTL Volume Batterv Power 4 RTL High Volume I RP Area Onsite Low Volume 2 RP Area

7-20 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 7-l Page2 of 2 Radiation Monitorins 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 Grisker) Automatic Whole Body N/A Contamination Monitors

7-2t DBNPS Post-Shutdown Emergency Plan Revision TBD Fisure 7-1 EMERGENCY FACILITIES BY GENERAL LOCATION SUPPORT AGENCIES COMPANY (OFFSITE / GENERAL AREA) (oFFSTTE) (oNSrTE) State of Ohio Joint Control Room Emergency Operations lnformation Center (cTRM) Center (EOC) (Jrc) Davis-Besse Ohio Emergency 623'Elevation Management Agency Toledo Edison Plaza 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 FirstEnergy Corp. Third Floor Port Clinton, Ohio Toledo, Ohio Facility Technical Support Emergency Center (TSC) Nuclear Regulatory Operating Facility Radiological Testing Commission (NRC) (EOF) Laboratory (RTL) Operations Center Lindsey Emergency Davis-Besse Response Facility Lindsey, Ohio Administration Building Rockville, Maryland First Floor (North) lncident Response Federal Emergency Site Emergency Center (lRC) Operations Center Operations Center NRC Region lll DOE, COO (sEoc) Lisle. lllinois Argon, lllinois Davis-Besse Administration Building Areva, NP Bechtel Power First Floor (Center) Corporation

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Lynchburq, Virginia

8-l DBNPS Post-Shutdown Emergency Plan Revision TBD 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 -Ceneral Plant Manager has been assigned the overall responsibility for emergency preparedness as related to the DBNPS. This responsibility includes not only maintenance of the DBNPS Post-Shutdown 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 -Ceneral Plant Manager is also responsible for haining of personnel who implement the Plan and Procedures. To assist the General Plant Manager in meeting these assigned responsibilities, an Emergency Response Manager, has been designated. The specific responsibilities of the Emergency Response Manager are described in the following subsections; and in particular, subsection 8.1.3. 8.1 OrganizationalPreparedness 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 General Plant Manager. This training program provides for the indoctrination of Company employees and contractors. In addition it provides specialized training for CFHs, chemistry personnel, radiation protection personnel, and personnel assigned specific responsibilities in the ERO. The General Plant Manager is responsible for ensuring that personnel in each department receive the appropriate training. The Nuclear Group Department Directors are responsible for identifuing training required for each individual's job specialty. Training in support of the Post-Shutdown Emergency Plan, includes the following:

a. All DBNPS staff personnel requiring unescorted access will receive industry standard training for unescorted access to a nuclear power plant and any specific training determined by DBNPS post shutdown.

b. Personnel assigned to the DBNPS ERO with specific Post-Shutdown Emergency Plan duties and responsibilities will receive specialized training for their respective assignments. Table 8-l 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 Post-Shutdown Emergency Plan and Emergency Plan Procedures. Davis-Besse financially supports the State of Ohio and the county

8-2 DBNPS Post-Shutdown Emergency Plan Revision TBD 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:

l. Interface with the nuclear security force during emergencies.

2. Basic health physics indoctrination and training.

J. 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 Post-Shutdown 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 Post-Shutdown 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/facility tour.

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:

Ensure that the participants are familiar with their duties and responsibilities. 2 Verifu the adequacy of the DBNPS Post-Shutdown Emergency Plan and Emergency Plan Procedures. J Test communications networks and systems. 4 Check the availability of emergency supplies and equipment. 5 Verifo the operability of emergency equipment.

8-3 DBNPS Post-Shutdown Emergency Plan Revision TBD The Emergency Response Manager is responsible for the planning, scheduling, and coordination ofall emergency preparedness related drills and exercises. All drills and exercises are subject to the approval of the General Plant Manager Each drill requirement will be performed within the specified time interval, with a maximum allowable extension not to exceed2s% 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. lnstructions 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.

8-4 DBNPS Post-Shutdown Emergency Plan Revision TBD b When a major drill or exercise is to be conducted, the Emergency Response Manager will: I Assign personnel to prepare a scenario. 2 Coordinate efforts with other participating emergency personnel, organizations, and agencies. J Obtain the approval of the General Plant Manager (DB). 4 Schedule adate 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 oftraining 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 Emergency Response Manager will noti$, 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 Post-Shutdown 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 Emergency Response Manager by observers or participants. The Emergency Response Manager 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 Emergency Response Manager.

8-5 DBNPS Post-Shutdown Emergency Plan Revision TBD

c. Records will be maintained on each drilVexercise 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/inj ured 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 l-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 Post-Shutdown Emergency Plan Revision TBD 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, facility 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) Radiation Monitoring Team (RMT) 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.

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 Emergency Response Manager The Emergency Response Manager shall ensure that:

a. Information, data, and procedures detailed in the Emergency Plan Procedures are consistent with the DBNPS Post-Shutdown Emergency Plan.

8-7 DBNPS Post-Shutdown Emergency Plan Revision TBD

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 Post-Shutdown Emergency Plan and Emergency Plan Procedures with the: I State Plans 2 County Plans J 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.

o E' Periodic reviews and updates of the DBNPS Post-Shutdown 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.

1. 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 ofpreparatory 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 Post-Shutdown Emergency Plan Revision TBD 8.2 Educational Information for the Public For those members of the public residing within the l0-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 ofthe 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 lO-mile Emergency Planning Zone. 8.3 Review and Update of the Post-Shutdown Emergency Plan and Emergency Plan Procedures DBNPS maintains, as separate documents; this Post-Shutdown 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 l, Final Safety Analysis Report (FSAR), will be maintained as a separate document. This is more clearly defined in the Updated Safety Analysis Report (USAR). 8.3.1 The DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan will be reviewed annually by an independent group with no immediate responsibility for the emergency response program. This group is the FENOC 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 Post-shutdown Emergency Plan to verifu compliance at least once every two years. The CNRB performs this function by reviewing the audits which are performed by the FENOC Oversight organization. The report on the adequacy of the interfaces between the DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan at least annually to verifu compliance with the company's internal rules and procedures, federal regulations, and operating license provisions. Personnel

8-9 DBNPS Post-Shutdown Emergency Plan Revision TBD performing audits of the DBNPS Post-Shutdown Emergency Plan and/or Emergency Plan Procedures will take into account corporate policy, state policy and plans, county plans, and the various agreements and 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 Post-Shutdown Emergency Plan and Emergency Plan procedures will be reported to the General Plant Manager. 8.3.3 The Emergency Response Manager will provide an ongoing review of the Post-Shutdown 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 Post-Shutdown Emergency Plan will be similarly controlled.

b. The Emergency Response Manager is responsible for coordinating the periodic review and audit of the DBNPS Post-Shutdown 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 Post-Shutdown Emergency Plan and amendments thereto, and the Emergency Plan Procedures and revisions thereto.

8.4 Maintenance and Inventory of Emerggncy Equipment and Supplies The Emergency Response Manager 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 willbe maintained in accordance with approved DBNPS procedures. Equipment, supplies, and parts having shelf lives shall be checked and replaced as necessary.

8-r0 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 8-1 Sheet I of 3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL PersonnelCatesorv InvolvedPersonnel Traininq and Frequencv Certified Fuel Shift Managers Certified Fuel Handlers receive extensive on-the-job and Handlers S formal training as scheduled and conducted by the CFH Other Certified staff training progftIm. This program includes a members comprehensive review of the DBNPS Post-Shutdown Emergency Plan and the Emergency Plan Procedures. Personnel responsible Emergency Director, Training will include the Post-Shutdown Emergency for assessment of Emergency Plant Plan, Emergency Plan Procedures, Technical emergencies Manager, Emergency Specifications (that are referenced in the Emergency Offsite Manager, Shift Action Levels), and other station programs, plans, and Managers, Key procedures. The listed individuals attend at least one Emergency Response meeting per year to receive training on the Post-Personnel Shutdown Emergency Plan and Emergency Plan Procedures. Detailed instructions with special attention Staffpersonnel given to the use of either dose assessment or engineering designated by the assessment techniques is provided based on the role they General Plant are expected to play during an emergency. Personnel Manager who may act shall participate in scheduled exercise and drills as OSC and TSC depending on availability. Managers 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. TABLE 8-1 Sheet 2 of3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL PersonnelCategory InvolvedPersonnel 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.

8-l 1 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 certiffing 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 ofthe 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 Post-Shutdown 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 Post-Shutdown Emergency Plan Revision TBD TABLE 8-1 Sheet 3 of3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL PersonnelCatesorv InvolvedPersonnel 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 offire fighting procedures and techniques shall be included in the training progrcm. 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 ofFleet 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 Post-Shutdown Emergency Plan Emergency Response Emergency Response Periodic classroom training and seminars on Emergency Personnel Manager and Response shall be provided on an as-needed basis and at designated staff the discretion of the Emergency Response Manager to these individuals from qualified outside organizations and documentation of this training maintained by the Emergency Response Section.

9-l DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Plant Manager, and coordinated by the Operations Support Center (OSC) Manager and the Emergency Radiation Protection (RP) Manager. 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 facility 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, cal ibration). 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 o

b. Decontamination requirement

h. Communications requirements

9-2 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 facilities.

d. Isolating and posting of areas in the facility 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 Plant 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. Following a SITE AREA or GENERAL EMERGENCY, the CompanyNuclear Review Board (CNRB) will participate in the recovery planning effort to assure that all nuclear safety aspects ofthe 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. The Emergency Plant Manager, under the direction of the Emergency Director, will be responsible at the site for coordinating onsite recovery activities and the return to normal status. At the time that an emergency has been terminated, and Recovery has been initiated, the Emergency Offsite Manager will be responsible for providing notification to 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 Plant Manager and the Emergency 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, andlor 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 Post-Shutdown Emergency Plan Revision TBD c Facility 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. (} The SFP is in a stable safe condition and long-term spent fuel cooling is b. 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 systems required to maintain SFP cooling, 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 significant damage to the SFP or damage to the spent fuel resulting in a radiological release, 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 facility 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 Post-Shutdown Emergency Plan Revision TBD 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. ln the final phase of the recovery operations, a restoration program will begin. The overall purpose of the restoration program is to return to safe storage of spent fuel. This program will include a detailed incident analysis. Determinations will be made as to the repair work required to perform needed modifications to equipment and/or 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 ofevents 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:

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. J Coordinate with the CNRB to ensure adequate review of engineering activities and proper review and approval ofthe recovery plan and implementing procedures. 4 Coordinate the deactivations of emergency response facilities and personnel as appropriate. 5 Coordinate the integration ofavailable state and federal assistance into recovery activities. 6 Coordinate with offsite authorities, and provide support as required for offsite recovery activities. 7 Review all information released by the Public Information Organization.

9-5 DBNPS Post-Shutdown Emergency Plan Revision TBD

b. Outage Director:

I Reports to the Recovery Director. 2 Coordinates the development and implementation of the recovery plans and procedures, under the direction ofthe Recovery Director. 3 Directs all onsite activities supporting of the recovery of DBNPS. c Radiation Protection Manager:

l. Reports to the Outage Director.

2. Develop plans and inskuctions 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 facility radiation surveys, sampling, and shielding in support of waste system processing, facility repairs, and design modification activities.

6. Designate members of Reentry/Recovery Team(s) dealing with onsite radiological aspects ofthe 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 SFP systems and activities.

3. Provide a central point for the collection, retention, retrieval and transmission of facility 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 facility.

e. Operations Manager:

l. Reports to the Outage Director.

2. Direct recovery activities conducted by Operations personnel.

3. Provide recommendations to the Outage Director regarding SFP operations-related aspects of the recovery.

9-6 DBNPS Post-Shutdown Emergency Plan Revision TBD

f. Maintenance Manager:

1 Reports to the Outage Director. 2 Coordinate maintenance activities conducted in support of recovery.

              )       Designate members of the Reentry team, as appropriate to support maintenance

g. Offsite Recovery Advisor:

l. Reports to the Recovery Director.

2. Provides liaison with offsite agencies and coordinating DBNPS assistance with offsite recovery and assessment efforts, as requested.

a 5 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.

J 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 Post-Shutdown Emergency Plan Revision TBD FIGURE 9.1 RECOVERY ORGANIZATION F'RAMEWORK Recovery Director (Emergency Director) Advisory Support Group Company Nuclear Review Board Offsite Recovery Advisor Outage Director Company Spokesperson (Emergency Offsite Manager) (Emergenry Plant Manager) (Company Spokesperson) Operations Manager Radiation Protection Manager (Emerg Assistant Plant Manager) (Emergency RP Manager) Scheduling Manager Engineering Manager (TSC Engineering Manager) Materials Manager Maintenance Manager (OSC Manager)

A-l DBNPS Post-Shutdown Emergency Plan Revision TBD Appendix A POST SHUTDOWN EMERGENCY PLAN PROCEDURE AND RELATED DOCUMENT INDEX AND CROSS-REFERENCE

A-2 DBNPS Post-Shutdown Emergency Plan Revision TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page I of6 Procedure DBNPS Post-Shutdown Emergency Imnlementing Procedures Number Plan Section

l. EmergencyClassification RA-EP-o1500 4.1,4.2

2. Unusual Event RA-EP-o1600 4.t.4

3. Alert RA-EP-o1700 4.r.3

4. Site Area Emergency RA-EP-01800 4.t.2

5. General Emergency RA-EP-o1900 4.1.1

6. Emergency Management RA-EP-02010 5.1,5.2,5.3

7. Emergency Notifications RA-EP-021t0 6.1.1,7 .6

8. EOF Activation and Response RA-EP-02220 5.5.2,6.1.2,7.0,7.2

9. Dose Assessment Center Activation and RA-EP-02230 5.5.2,7.2

Response

10. FENOC MIDAS Dose Assessment Software NOP-LP-s400 6.2 I l. Davis-Besse MIDAS Dose Assessment NOP-LP-s402 6.2 Software

12. DBNPS MIDAS Multiple Accident Dose NOP-LP-5412 6.2 Assessment Software

13. Offsite Dose Assessment RA-EP-02240 6.2

14. Protective Action Guidelines RA-EP-02245 6.4

15. FENOC Field Monitoring Teams Radiation NOP-LP-5o15 6.2,5.5.2 Monitoring Teams Field Surveys

16. DBAB Radiation Monitoring Team RA-EP-02252 6.2,5.5.2 Surveys

17. Radiological Controls in the DBAB RA-EP-02260 6.4.1,6.4.2,7.2

18. Facilities Support RA-EP-02270 7.0

19. TSC Activation and Response RA-EP-02310 5.4.4,7.2

20. Emergency Technical Assessment RA-EP-02320 6.2

21. OSC Activation and Response RA-EP-02410 5.4.5,6.4.2,7.1.2

22. Search and Rescue RA-EP-02420 6.4.1

23. Emergency Security Activation and RA-EP-02510 5.3.4,5.4.4,6.4.3

Response

24. Assembly and Accountability RA-EP-o2520 6.4.1

25. Evacuation RA-EP-02530 6.4.1

26. Offsite Personnel & Vehicle Monitoring & RA-EP-02550 6.4.1 Decontamination

27. Emergency RP Organization Activation RA-EP-02610 5.4.4,5.4.5 and Response

28. Emergency Exposure Control and RA-EP-02620 6.5.1,6.5.2 Potassium Iodide Distribution

29. Station Radiological Surveys and Controls RA-EP-o2640 5.4.5,6.5 During Emergencies

30. Reentry RA-EP-027r0 9.1 3 1. Recovery Organization RA-EP-O2720 9.2

A-3 DBNPS Post-Shutdown Emergency Plan Revision TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page2 of 6 Procedure DBI\IPS Post-Shutdown Emergency Off Normal Occurrence Procedures Number Plan Section L Medical Emergencies RA-EP-02000 2.7, 5.8.2, 6.5.3

2. Preparation and Transport of Contaminated RA-EP-o2800 2.7 Injured Personnel

3. Emergency Helicopter Landing Zone RA-EP-o2807 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-o2840 2.6.5,2.7,7.10

8. Hazardous Chemical and Oil Spills RA-EP-o2850 2.6.5,2.7,7.10

9. Radiological Incidents RA-EP-02861 2.6.5,2.7,7.10

10. Station Isolation RA-EP-o2870 2.6.5,2.7,7.10 I l. Intemal Flooding RA-EP-o2880 2.6.5,2.7,7.10

12. ERO Response to Security Events or Threats RA-EP-O2890 2.6.5,2.7,6.4.1 Administrative Procedures

l. Emergency Plan Training Program RA-EP-00100 2.7,8.1.1

2. Emergency Response Organization Training NOP-LP-s006 2.7, 8.1.1 Program

3. Emergency Response Drill And Exercise Program NOP-LP-5o1I 2.7,8.1.2

4. Emergency Planning Activity Scheduling RA-EP-00300 2.7 System

5. FENOC Siren Testing And Maintenance NOP-LP-5005 2.7,7.8 Procedure

6. Maintenance of Emergency Plan Telephone RA-EP-0051 0 2.7,7 .6.3 Directory

7. EmergencyResponse Organization RA-EP-0o520 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 I l. 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 1 4. Comput erized Automated Notifi cation System RA-EP-04003 2.7,8.1.2 Weekly Test 1 5. Emergency Facilities Communication RA-EP-0401 0 2.7,8.1 .2 Quarterly Test

A-4 DBNPS Post-Shutdown Emergency Plan Revision TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 3 of6 Public Information Procedure

1. JIC Activation and Response RA-EP-02950 2.7, 4.3.3, 5.5,7.2,9.3 Supporting Documents

l. Fleet Support of Emergency Plans at FENOC NOBP-LP-5001 8.3, Table 8-l Nuclear Plants

A-5 DBNPS Post-Shutdown Emergency Plan Revision TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 4 of6 I\UREG DB Post-Shutdown NT]REG DB Post-Shutdown Emergency Emergency 0654 to Plan Section 0654 to Plan Section Ala 2.8,5.8, Table 2.1 Frd 7.6 Alb 5.r - 5.8 Fle 6.1.2,7 .6.1 Alc Table 2-l Flf 7.6 Atd 5.2 F2 7 .6.3,7 .8 Ale 5 .l .2, 5 .l .3, Table 5. I F3 8.1.2 A2a N/A GI 8.2 A2b N/A G2 8.2 A3 App.c G3a 7.3.4 A4 5.0 G3b 7.3.4 BI 5.3 G4a 5.2.4 B2 5.2.1 G4b 5.5,7.3.4 B3 5.2.1,5.3.1-5.3.2 G4c 7.3.4 B4 5.2.1 G5 8.1.1 B5 5.0, Table 5-l H1 7.2,7.2.2 B6 Figure 6-2 H2 7.2 B7 Table 5-1, 5.6 H3 N/A B7a 7.0 H4 Table 5-1,7.6.1 B7b 7.2 H5a 7.9 B7c 7.2 H5b 7.9.6,7.9.8 B7d 7.2 H5c 7.9.9 B8 5.8.4 H5d 7.9.6 B9 5.7, App. C H6a 7.9.8 Cla 5.2.1,6.1.6 H6b 7.9.tl clb 5.8.3 H6c 7.9.t0 Clc 7 .6,7 .9 H7 7.9.tl CZa N/A H8 7.9.6 c2b 5.5.2 H9 7.r0 C3 7.9.10-7.9.12 Hl0 7 .12,8.1.3 C4 5.8, App. C H1r 6.4.2,7.12 D1 N/A (NEr e9-01) H12 7.9.10 D2 N/A (NEr 99-01) II 4.0 D3 N/A D4 N/A t2 7.9 EI 6.1,7 .6.2 I3a 4.0 E2 6.1 r3b 4.0 E3 6.1 T4 4.0 E4 6.0 I5 7.2,7.9.8 E5 N/A I6 7.9.8 E6 6.4', T7 7 .9.11 E7 6.4 I8 7.9 Fla 7.6 I9 7.9,Table 7-4 Flb 7.6 rl0 7.9 Flc 7.6 I 11 N/A

A-6 DBNPS Post-Shutdown Emergency Plan Revision TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 5 of6 NUREG DB Post-Shutdown I\IUREG DB Post-Shutdown Emergency Emergency 0654 to Plan Section 0654 to Plan Section Jla 6.4.1 K6c 6.4.3 Jlb 6.4.1 K7 6.s.3 Jlc 6.4.1 L1 5.8.2,6.5.4,6.5.5 Jld 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-l J6a 7.9 M3 9.2 J7 6.4.1 M4 9.2.3.c.3 J8 App.D Nla 8.1.2 J9 N/A Nlb 8.r.2 J 10a App.D N2a 8.r.2 J 10b App.D N2b 8.t.2 J lOc 7.7 N2c 8.r.2 J lod N/A N2d 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 l0g N/A N3a 8.1.2 J loh N/A N3b 8.1.2 J 10i N/A N3c 8.r.2 J 10j N/A N3d 8.1.2 J 10k N/A N3e 8.1.2 J 101 N/A N3f 8.1.2 J lOm 6.4.1, Table 6-l thru 6-6 N4 8.1.2 J 1l N/A N5 8.1.2 lt2 N/A 0l 8.1.1 Kla 6.5.3 0la 8.1 .l Klb 6.5.1 0lb N/A Klc 6.s.1 02 8.1.1,8.1.2 Kld 6.5.3 03 8.1.1, Table 8-1 Kle 6.s.3 04a 8.1 .l K1f 6.5.4 04b 8.1 .l K1g 6.5.5 04c 8.1 .1 K2 5.2.1,6.5.1 04d 8.1.1 K3a 5.2.1 04e 8.1 .l K3b 6.1 04f 8.1 .l K4 N/A o4g 8.1.1 K5a 6.5.3 04h 8.1 .1 K5b 6.5.3 04i 8.1 .1 K6a 6.4.3 04j 8.1 .1 K6b 6.4.3 05 8.1 .l

A-7 DBNPS Post-Shutdown Emergency Plan Revision TBD Post-Shutdown Emergency Plan Procedure and Related Document Index and Cross-Reference Page 6 of6 I\IUREG DB Post-Shutdown IYT]REG DB Post-Shutdown Emergency Emergency 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, 9.3 P8 App.A P4 8.3 P9 8.3 P5 8.3 Pl0 7.6.3

B-l DBNPS Post-Shutdown Emergency Plan Revision TBD Appendix B Department of Energy Emergency Radiological Assistance Program (DOE O 1s3.1) for FirstEnergy Corporation Davis-Besse Nuclear Power Station (Reference to DOE O 153.1 is available Online at: www.directives.doe.gov)

c-1 DBNPS Post-Shutdown Emergency Plan Revision TBD 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 Ottawa County Commissioners Ohio Department of Public Safety Emergency Management Agency

c-2 DBNPS Post-Shutdown Emergency Plan Revision TBD EME&GENOT RESPONSE AGRBEIT.IENT This fureemert msdt and eiilercd inm by and betrryecn FirstEnergy (horcinnftcr "Utility) and thg Canoll Tor+nship Emcrgcmcy Medical arrd Fire $enice" Iac., in consldemtion of tha following: I The Canoll Township Emergrncy lvldical and FIrc $crvice, Inc.,

                              *Service, Inc,') sgrcss t* ure equlpmcnt availsble to it to Ocrcinafter provide tweaty-fuur (2a) hour emergenoy arnbulance and fire proteetion for actual   emergencies, including hostilc action event$ 6t Davis Besse Powu Stalioq drills and trainlng activities at FirstEncrgy, located within fte jurisdistioaal boundarry of Cardl Township, Ottrawa County, Ohio, all subject to the aorual emergeosy needs of thc whole Township. When neocssary    lo provide such actual cmcrgcncy       service, $ervicc, Inc.,  will rcqucst any muhral aid or s$sislancc, a$ msy be necessary sfld that rnay be availnblc from surroundiug communities"

2. TIre Utility shall provirlc Service, Ine., wilh any supplies and additional Oquffient or ur,odifications to current equiprnent that may be neec*sary, as determined ba$ed upon the nrultml agrcement of the Utility and Servicc, Inc., for $crvicq Iac., to fulfill itt obligations hcreundsr or t0 mct lhe rcquircmenls of the Nucleu Regulatory Commisclon that may apply to this Agreement; if the rccessary equiprncnt is nol provided to $crvicc, Inc., try Utility, then the obligation* hereunder reguired of Scrvice, Inc.,

arc waived and Seryicc, Inc., shnll not be required in any fashion to fulfill the obliga.tions hcrcol, nor shnll Seryicc, Inc.. bc liable for failing to fullill said obligations. Any equipmcnt provided hy the Utility to Scrvice, Inc., slmll bc stored aud maintainsd at the discretion of Scrvice, Iuc.. 3 $urther, ths Utility agrees to assttme all cxpenses aftl sosts of providing specializcd training for participating personnei nnn is to improve your lrealth an<l well^beinE, llovember 28,2017 Mr.Jemer M. Vtter Manager - Emorgeniy PrpBredness Dayis-Besse Nudear Power Statlon s5(u stat Route 2, Mallstop 3060 Oak Harbor, Ohio l3tta9-9?60

Dear Mr,

Vetter, Thi: letter reaffirms our cormitment of lune 30, 19118 that ProMedier Memorial Hospital will accept casurlties arisirg fmm ndiatim accidents at the Davb-Besse Nudear Porer Station. It ls undeBtood thtt FkstETcrW h flnanclally respolslble for arry modlffcatiom to thc rxisting hoipitrl facility, which may be rcqoired for reguhtions of the Nuclear Regulatory Commission, or others, for the treatrnent of patients expoced to radioactivE materials. This also inchdes tralnirq of hospltal personnel a3 may be requlred and for speclal equlpment ar may be necessary, It is further understood that written procedures detailing the act'pns to be fullotred fior thc care of these patlenb wlll be lmplemented and that our personnel will cgntlnue to recelve ldstructlons regardlrq thls plin of actlor and wlll male perlodlc'dry rurs: as needed. This agreement shall remain in effect unlil termlnated ln wriUrg by either party thirty {301 days prior to the effective date. Sincerely, Pam Jensen, ProMedica Memorial Hospital

c-l I DBNPS Post-Shutdown Emergency Plan Revision TBD fi:MBncv (-rrc rut mn hdim irf l/a{:J l;1. Ame FIastrlB July 29, 2015 lr'!(il lil. DEhE llospild lr,rlt  :;1 U.snt rrkdr, (;r':5 Mr. James M, Velter ly'dcr CrldBrs Haspld i an{er- EmerBenry RcrPonJ lrurti ho:prd a*ftfiyq Davl*3eese Nuclcar Power Sutlon 5501 N. State Boutc 2, Mall Stop 306o ly'rrr :! I llh 1 -lQ-lf,J Oak llarbor OH 43449760 fy'irtr:t l4:ilrrC Hi$*r. lr.-'u, l"i-!.'r j,l J'aiEn Ihrr ML Vetter: This Lrfter of Agreanent rcalltrms our commihlenl, spccifrcd ln our mutusl atn6nent with First EnEy, that Mercy 5t. Cherle3 Horpltd will aimpt ctJusltier arblrg lrom radlataon acddents at tha Dav*-Besse iludear Powerstatbn' It is understmd thst Flrst Enc'f,V b flnancir[y respooshh fior any modificatbns of the ExlSt',rE hospit3l hcility whlch may be reqrdred by rcguhtloos or otficr Suidrnce of $e Nudear Reguhtory CommBsbn (ilRCl ortln Fcdanl tmeqency Mrn4ement Agency (FEMAI for the tmatmcnt of patlents crposed to radbactlve materi.b. Thb also lncludcs trainlng ol hospital personnel as may bc ruquired, and ior spc*l eqdrnent as mry br neo?s$rY. It b furltrer undectood that wrinen procedurcs detailnt the acthns to be blkxred for tte care of these patl-ents lf,ill be lmphmentcd and th.t ou] pcaonnel ursl continue to reeive lnstructions rqardirg thls plan of actlon and wtl make periodk "dry runf as needed. This rgreement shall remaln ln effect untll terminatcd kr writing by cltlEr party thlrty (30) d.ys prior to the effectlve date. Slnoerely,

                                            /4AAlt^^4)

Cralg Albers, RN

                                          \4ce Prtsident, Patient Care/CNO Mercy St. Charles HosPital Agreed    to:

{-?ts-M. Vetter Dat?

                                                      , Emergency ResPonse Davis-Besse Nuclear Power Statlon

c-12 DBNPS Post-Shutdown Emergency Plan Revision TBD

c-13 DBNPS Post-Shutdown Emergency Plan Revision TBD Ottawa

                                  -Comly Emcrycnq Mnnlgcmcnl Aryncy                            Officu             ,tlr-I!+69m 315 MadEon Strret, Annex Basement                                           counlprildr:       800-ru8-8s03 l:i   i'-'.

ttn cllnlon, Ohlo,l345l- t936 Frc$mlle lt9"2t9-236t MTD PETE,RSEN. DTCCIOT

                                                                                                     $dc ruen8co.oll       ruanlr.w urri v.codtffuri&o   h,u   #otlcrroc ocmr Scplcmbcr{, t014 lrt. ,ifite1Yltlgr, t ncrEtncy fltlf orrsr Mrnrgtr Drvll'Bfficn Nwhar Fowtr St*tlon 5501 Horth State Roure 2 Ork )lirbor, OH 43{49

Dear [i!r,

Vetter, Itc Ollrrye County lorr;mcy MrnrBelnenl rgeocy h the l*Erl rgsrxt ln otimt cou:tty for hlodlng ard coordlntthg rerponse t0 area-rrylilE emer3snciri ulrhln lir Couoty. As sudt fte OM$,q CountT tmEf8effi' Menagement umuH lead and coordlnatE couilty rEsomE lo en inddent il lhe Srvlt-Be.rrc l{uchar Poffcr^gency Stalion, Ollawa County hes da*loped pianr end gxrideli*s to deel wlth an emergency at Davftr-Ee$e Xudeer Powe/ St$thn,l*cludln3 hoillh ectloft and would tlslomrnt tb0[r plo.u lnd jddolln*t to thr bf}t o{ Its ablllty ln theevent of an hddent flt the plrnl, Th Courty krtends lo Frotect the healtlr rutd ursllare ol tile people in Otteurd Courrtf, tlrmugh the knplem+fitrUoo of llr rergonse plsm ond guldellne* Thh httcr oI ngre*rn+nt l$ not lnt0fldGd, cnd shall rlol l,t conitrurd re acrUng Eebfllty on the plrt o, lhe County of Otlatra, and of its a6erxles, er of lh offken, ageiilF Gd erpbyees l$ereof. Thh agreemtnt wlll bo rctkwed rnd, ll nnomrtry rcyttd on 6n rnnuill hash ln accordrnca yriUt NllStS'0b$4, ll no reulsionr are neoairary, lhb agreanant ivll rcmfflfl ln effuct ur]*s tcrmlnated by eilher party gMng nlnety (901 days a&ance, writlen nstlq ol lermlnatlon to the other Farly, BoARU otj oI IAWA coufl rY coMrdt5$K),r,,tH5 OTIAVJA COU!{W EMEfiGCTT{Y MANASEMEIIJT AG i'JlL;fu*:,, , fi,uy.il /torllen ttegal, pierlilent frcd Fetersrn. EldA Dlreetor rLl. f tlrl M 5a f';c#; lsrioncr fl tlF,f.tutrtr:f.l At'i'tl I rlfr [t : Ste*n lr'1. Arndt, onrnissioner { r/v/tY [q],lt {:r. illfilJ,,.l-.1 l:t ror ecu tl rr 1tr litt rr rtr +y (,?ttittru $rrt;rrl y, i,',k lti

c-t4 DBNPS Post-Shutdown Emergency Plan Revision TBD OH]o OEPARTT{EFrT &tun xrriltroorr,lrr OF FUELIC SAFETY (8Y-laNraa.al.8Ei Untu

                                         . lrQlryIrqfiitlllroy                                                   &*ntr!l' ntar r  3mqmrtft,Fr$\ftr
                                         . alflbdglt{rlJrr&Bmbr                                     &ill![ry l.mrgrtt:illrr,
                                         . OiloHfiSIrlstqilt                                        2t65ftbcDtr.rn*fh.d r  lhlolnrrtdaljll                                             Oofillrhr, olt {ita.i:flt r   OlSAtHElrtEyprrml                                                       lct{ tta-rlt{,

w.a!l!.!ah{o, Decembcr 2, 2013 Itlr. GhoD McKoo _l_ First Eoef5/ Ngclear Operrring Cornpany - i - 341 lVhih Pond thiw (wAC B.t) Akron,Ohio44320 Dear Mr. McKrcl In order for drc StaE of Ohio to nmain in complimoo widr Fdeill rcgul*ioaa ths a$Eblirh;d Mcruorandum of UndffsErding (MOU) botwooa ttn Slab of Ohh rnd Firct fncq5/ Nuclcar Opcraring Compagy^([ENOC) hst beeo rcvlcqrcd rogading the ooordinatioo of off-rlto ,*por,* ti-n,nlerr inciriomr for P*o Vallcy Powr Stetion @YPS), Devis.Besse Nuclcr Powur Strtior tMtnSl end Perry Nuclcar Powcr?lant (n\rPP). Thc agrmrneut is io lsordfiDc wih thc Nrrcleer Rogulatory Commissiyr

                                                                                                           $mC;     *a Fcdaral Emugency Manrgcmecrt Agene? (fEltA) guidence ar oulinod in t'runA+Oe5,ilFEI\iA-REf-t, It*ision I. Enclosed pu will find a copy oftrc most mceirt doeumcut Thc purposo of this leller is to inform 1ou ilre sgrtrncilt bGhr!6rl $a Statc of Ohio and tt I'ENOC nue rwicwtd and rcorains in cffcct, Tl! Stste fur&eracknowlodgss Orc MOU rllill omtiaue to rcmdn in full fotto qrd cffet until such limc as sithcr of thc portice dccidcs thcageemmt needr to be rcvired Fach ycr, lho MoU uill bc rcvicwed for substlltivo chrngas md up&red-as rcocisrry. Baning rny substantive cftangcs, the MOL will ra,nrain in efhet Sig;rAry confrmntion is not requirod,
           -tf you do not agrw *'idr this mviarv   prroocss or wisb to make changos to tlrc MOU, ptc*ro contact Mr" Yidry! Beqofmy statrd 6l+799-36E7, If th pl,,ocssl is acocptablo u"a pu hrvc                oo cianger, you ueed ro do nothing. Please let us know lfpu haw eny questioor in this regud. n irt 1aorr.

Sinoerely, h'ancy J. Exccutivc Dirsctor fnclosure

c-I5 DBNPS Post-Shutdown Emergency Plan Revision TBD LTTIM, OT AGREEMENT BETHMEI{ rmrir EI\IERGY ruCrr*N OPSNATING CSIIIPANTY AIYD TEA OEO DEPARIITMIIT OT PI'BLIC $ATETY Effi RGXNCT IWANAGEN'ENr AGUI{CY Ihic l!*ta will eerve as_ a urifien agrccoont ut-th" (Ilavis-Bocao .t

                      }ftrslearlornr Stado& Pmy Nuclear      Iir"t Bnergr l'h,rclcr Oprating cbmpalpr Powcr Plail, rna nerver van{ rowil IH:P f ryvide the ohio Dopamem ofpublic srftty, rmqorroy Managrolcot Aeecy wrln  tDE  fbuowing equipnral rt
                 .iu.

ffre locdions indioateddruing a drill or ometgcncy invoftiug a nuclear powcrplant. lOCAnoN: BOUIIMEI{T JPIC: TelqphmE's, Fa*imile lvfechinc, Copicr, Typewritar/lilonl Processor, Wolt Spacq Strtus Boslds. h.frys, Adminishative Supportffirrpptior ECffio$': Tclcphones, FamimilaMachin, copro, Tirorkspace, stailrsBouds,Maps, Adminishtivc $upportAirrypHcr NOTE: It is understood that tbis listis mt atl incfurivq but ie rcpmsonlativc ofrhelevcl of

  *upport needed by rmponders to thsc fscilitics A tcchdcal liaison will be diqpalche.l by ee FiretEnury Nuolear Oper*tng Company to lhe Statc Emcrgency Operations Contor (EOC) upon orbcfura thc dcclaration of a Site e"cr Emergmcy at Davis-Bess NuclcarPowu $tation, Perry Nuelcr Powcr Plrrg or Beaver Valloy Povrer Station as dctermined by iodividual plant procedures. The State will providc Eimilar equipo*at to the techdcal liaieon to srsrre hia/her dulio* mey bo prformed. trn the evcnt of sr incide'nt whcrc frrrther degrrdation ofthe plmt appcarrs tikcln trc btio Emoqgency Manage$rnt fSer:cV &oy rquest that the techicd liaiao:r be dispahhed to the State EOCprio;to a Sie Aroa Emsrgency declaratioa. Tlro Ohio Emagmcy MarugemEut fuency will dispatc'h a liai5on to the nuclear porvcr plant of corcem al lhc Alert lwel, This agreancnt shall be reviewod annually and updated as $occsasrl. Thc agreernent will rcmain in effcct until terminated by cittrcr p*ty thrcugh the auhnission of a-sixty (60) daye r+ritlen notice, SIGNED                        -i-Ior lhe State of OhIo Ernelgency                                For the [irst Encrgy Nuclear llanagcment Ageney                                                     Operating Compauy Cf,IEf,       fI}IG OFI'ICf,R -  PEilOC
                ,4:

ff.q,Tg DATE

D-l DBNPS Post-Shutdown Emergency Plan Revision TBD 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 #IO, HAZARDOUS MATERIALS, TAB B _ REP INCIDENT RESPONSE PLAN OTTAWA COLTNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN LUCAS COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN

E-1 DBNPS Post-Shutdown Emergency Plan Revision TBD Appendix E (Under Separate Cover) DBRM-EMER-l5O0 A, Davis-Besse Emergency Action Level Basis Document

F-l DBNPS Post-Shutdown Emergency Plan Revision TBD Appendix F (Under Separate Cover) Davis-Besse Nuclear Power Station (DBNPS) ERO Post-Shutdown On-Shift Staffing Analysis Report

Attachment 4 Emergency Response Organization Task Analysis (11 Pages Follow)

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Attachment 5 List of Regulatory Commitments (One Page Fo!!ows)

List of Regulatory Commitments The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for the Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by FENOC. They are described only as information and are not Regulatory Commitments. Please notify Mr. Thomas Lentz, Manager, FENOC Nuclear Licensing and Regulatory Affairs, at (330) 315-6810 of any questions regarding this document or associated Regulatory Commitments. TYPE SCHEDULED ONE.TIME REGULATORY COMMITMENT CONT!NUING COMPLETION ACTION COMPLIANCE DATE

1. Plant activities that could cause mechanical x Prior to permanent damage will require the radiation monitor removal of fuel from listed in gaseous effluent emergency action the DBNPS reactor levels (EALs) be in service or that a vessel.

Chemistry Technician be onsite, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. Applicable fuel handling procedures will be revised to require that the radiation monitor listed in gaseous effluent EALs be in service or that a Chemistry Technician be onsite as a prerequisite prior to fuel handling activities.

2. To validate the results of the proposed x Prior to changes to the ERO described within this implementation of the amendment request, FENOC will perform a Post-Shutdown drill to confirm the ability of the Post Emergency Plan Shutdown on-shift and augmented emergency response organization to perform the necessary functions of each emergency response facility and to utilize the post-shutdown procedures being developed, depicting the revised assignment of duties.

The drill will evaluate the ability to accomplish the stated mission of each ERF and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. State and local response organizations will be provided the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.

Enclosure B L-18-271 State and County Reviews (Three Pages Follow)

i,i .t' ',1,,i, [,(_) Lil."l i'Y Board of County Commissioners Pete Gerken President Tina Skeldon Wozniak Carol Contrada Emergency Management Agency Patricia R. It'loome1, Director December 3,2018 Mr. Sean Zalesny Manager Fleet Emergency Preparedness FirstEnergy Nuclear Operating Company 341 White Pond Drive Akron, Ohio 44320

SUBJECT:

Davis-Besse Nuclear Plant Post-Shutdown Emergency PIan Based on our discussions during our meeting on November 29,2018, conceming FENOC's Post Shutdown Emergency Plan License Amendment Request for Davis-Besse Nuclear Power Station, we are satisfied we undcrstand the changes proposed and we are satisfied that these changes will not irnpact the ability of Lucas County Emergency Management Agency to effectively implement our FEMA approved REP plans. Sincerely Patricia R. Moorney Director' Lucas County EMA 2144 itloruoe Strcet . Toledo, Ohio 43604 (419) 213-6506 http://co.lucas.oh.tts Fax:(419) 213-6552 Att I kyt ttl O pllot'ttttlil' Etttltlol'er

Ottawa County Emergency Management Agency Office: 419-734-6900 315 Madison Street, Annex Basement Counhywide: 800-788-8803 -1"1,,' Port Clinton, Ohio 43452-1936 Facsimile: 419-249-2361 FRED PETERSEN, Director http://www. co. ottawa. oh. us/ottawacoema/index. html December 6,2018 Mr. Sean Zalesny Manager, Fleet Emergenry Preparedness FirstEnergy Nuclear Operating Company 341White Pond Drive Akron, OH 44320

Dear Mr. Zalesny,

Based on our discussions during our meeting on November 29,20L8, concerning FENOC's Post Shutdown Emergency Plan License Amendment Request for Davis-Besse Nuclear Power Station, we are satisfied we understand the changes proposed and we are satisfied that these changes will not impact the ability of Ottawa County Emergency Management to effectively implement our FEMA approved REP Plans. Sincerely, Fred Petersen, Director Ottawa County Emergency Management Agency}}