BVY 04-038, Change to the Emergency Plan, Revision 39

Change to the Emergency Plan, Revision 39

ML14339A663
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/28/2004
From:	Tkaczyk L Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 04-038, FOIA/PA-2015-0012
Download: ML14339A663 (187)

Text

TREAT AS SENSITIVE INFORMATION

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Vermont Yankee v-mEntergy 322 Governor Hunt Rd.

P.O. Box 157 Vernon, VT 05354 Tel 802-257-771 1 April 28, 2004 BVY 04-038 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Vermont Yankee Emeraencv Plan Chanues In accordance with 10 CFR 50.54(q), enclosed is the latest change to the Vermont Yankee Emergency Plan, Revision 39, including the change memo and the 10 CFR 50.54(q) Evaluation Checklist.

These changes were determined to not need prior NRC review and approval.

If you have any questions, please contact Audra Williams, Emergency Planning Coordinator, in our Brattleboro office at (802) 258-4177.

Sincerely, ori Tkaczyk; Emergency Planning Manager Attachments cc: USNRC Region I Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - .VYNPS (no attachments)

David M. Silk, Senior Emergency Preparedness Specialist, USNRC Region 1 Vermont Department of Public Service

\X -.5

ENTERGY VERMONT YANKEE EMERGENCY PLAN FILING INSTRUCTIONS April 28,2004 Change #43

• Note: Appendix A, EAL Drawing from AP 3125 will be revised separately.

Cover Sheet Replace E-Plan Approval Sheet, Effective Date 09/24/03 with E-Plan Approval Sheet, Effective 04/28/04.

Revision Summary Insert, behind Cover Sheet, Revision Summary page i of i Table of Contents Replace pages i-vii, Rev. 38 with pages i-vii, Rev. 39.

1.0 INTRODUCTION

Replace page 1, Rev. 38 with page 1, Rev. 39.'

2.0 DEFINITIONS Replace pages 2-4, Rev. 38 -withpages 2-4, Rev. 39.

3.0

SUMMARY

OF EMERGENCY Replace pages 5-8, Rev. 38 with pages 5-8, Rev. 39.

PLAN 4.0 THE AREA Replace pages 9-22. Rev. 38 with pages 9-22 Rev. 39.

5.0 EMERGENCY Replace pages 23-25, Rev. 38 with pages 23-25, Rev. 39.

CLASSIFICATION SYSTEM 6.0 EMERGENCY RESPONSE Replace pages 26-36, Rev. 38 with pages 26-36, Rev. 39.

FACILITIES AND EQUIPMENT

> 7.0 COMMUNICATIONS Replace pages'37-42, Rev. 38 with pages 37-42, Rev. 39.

8.0 ORGANIZATION Replace pages 43-68, Rev. 38 with pages 43-69, Rev. 39.

9.0 EMERGENCY RESPONSE Replace pages 69-77, Rev. 38 with pages 70-78, Rev. 39.

10.0 RADIOLOGICAL ASSESSMENT Replace pages 78-90, Rev. 38 with pages 79-91, Rev. 39.

& PROTECTIVE MEASURES 11.0 EMERGENCY NOTIFICATION Replace pages 91-93, Rev. 38 with pages 92-94, Rev. 39.

& PUBLIC INFORMATION 12.0 MAINTAINING EMERGENCY Replace pages 94-99, Rev. 38 with pages95-100, Rev. 39.

PREPAREDNESS APPENDIX A Replace page 100, Rev. 38 with page 101, Rev. 39. DO NOT REMOVE APPENDIX A. AP 3125, REV. 19 DRAWING.

APPENDIX B Replace pages 102-104, Rev. 38 with pages 103-105, Rev. 39.

APPENDIX C Replace pages 105-106, Rev. 38 with pages 106-107, Rev. 39.

APPENDIX D Replace pages 107-126, Rev. 38 with pages 108-110, Rev. 39.

APPENDIX E Replace pages 127-162, Rev. 38 with pages 111-146, Rev. 39.

APPENDIX F Replace pages 163-170, Rev. 38 with pages 147-154 Rev. 39.

j APPENDIX G Replace pages 171-173, Rev. 38 with pages 155-157, Rev. 39.

APPENDIX H Replace pages 174-182, Rev. 38 with pages 158-166, Rev. 39.

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Vermont Yankee 322 Governor Hunt Rd.

E n'PRO. Box 157 Vernon, VT 05354 Tel 802-257-7711 April 28, 2004 BVY 04-038 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Vermont Yankee Emersencv Plan Changes In accordance with 10 CFR 50.54(q), enclosed is the latest change to the Vermont Yankee Emergency Plan, Revision 39, including the change memo and the 10 CFR 50.54(q) Evaluation Checklist.

These changes were determined to not need prior NRC review and approval.

If you have any questions, please contact Audra Williams, Emergency Planning Coordinator, in our Brattleboro office at (802) 258-4177.

Sincerely, oriTkaczyk Emergency Planning Manager Attachments cc: USNRC Region 1 Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager -.VYNPS (no attachments)

David M. Silk, Senior Emergency Preparedness Specialist, USNRC Region 1 Vermont Department of Public Service

CONTROLLED DOCUMENT REVISION REQUEST FORM SECTION ONE: Rcquest for Current Document (Completed by Sponsoring Department)

(A) Controlled Document Title (B) Current Revision Number EMERGENCY PLAN REV. 39 (C) Sponsoring Organization (D) TypingCompletionNeeded(Date) (E) 3 Hard Copy (Allow sufficient processing time for DCC personnel) El Electronic EMERGENCY PLANNING APRIL 9,2004 (F) Originator Name (Print) Originator Signatur! . Date of Request Audra Williams 3/16/04 SECTION TWO: First Draft Typing (Completed by DCC)

I(A) DCC Date Received (B) Draft Completed by (C) Date Draft Completed 03iIahneo41 ,k)J MJ. Pi.e.L 4o I 03qh1/9lnnOi SECTION THREE: Approval and Distribution (Completed by Sponsoring Department)

(A) Proofread by Originator (print/sign/date)

Aucker VVI1Ltiar A m &UaJ2 32&a (B) Distribution Submission Date (C) Date Required for Issue (Effective Date) 4 (Allow 10 working days from date) 42 .8 -

(D) Safety Evaluation Per AP 6002, "Preparing 50.59 Evaluations" ElD50.59 Screening completed and attached, Safety Evaluation NOT required I El 50.59 Evaluation completed and attached W NIA (E) IOCFR50.54(q) Evaluation lX Emergency Plan: 10CFR50.54(q) evaluation completed per AP 3532 and attached

.I El Emergency Plan Implementing Procedure: 10CFR50.54(q) evaluation completed per AP 3532 and attached El N/A .

SECTION FOUR: Distribution (Completed by DCC)

Date Distributed 4/198og i  ;

VYAPF 6805.07 AP 6805 Rev. 20 Page I of I LPC #1

10 CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/Emergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.):

Emergency Plan, Rev. 39, Change #44 A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.

A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist.

A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist.

II YES NO l Could the proposed change affect our ability to meet the following standards of IOCFR50.47(b):.

(1) Assignment of Emergency Response Organization responsibilities X (2) Assignment of on-shift Emergency Response Organization personnel (3) Arrangements for Emergency Response Support and Resources , X -'

(4) Emergency Classification and Action levels, including facility system .~ X.

and effluent parameters (5) Notification Methods and Procedures X (6) Emergency Communications among principal response organizations X and the public (7) Public Education and Information x X' (8) Adequacy of Emergency Facilities and Equipment XX x I (9) Adequacy of Accident Assessment methods, systems and equipment (10) Plume exposure pathway EPZ protective actions

'X (11) Emergency Worker Radiological Exposure Control X

(12) Medical Services for contaminated injured individuals X

(13) Recovery and Reentry Plans (14) Emergency response periodic drills and exercises X (15) Radiological Emergency Response Training (16) Plan development, review and distribution VYAPF 3532.01 AP 3532 Rev. 11 Page I of 3

10 CFR 50.54(q) Evaluation Checklist (Continued)

YES NO

2. Could the change affect our ability to meet the following requirements of Appendix E to 10CFR50 (1) Section IV. A - Organization I. . X . . . .

(2) Section IV. B - Assessment Actions

-x (3) Section IV. C - Activation of Emergency Organizations Xx -

.I I

(4) Section IV. D - Notification Procedures X I (5) Section IV. E - Emergency Facilities and Equipment X I (6) Section IV. F - Training .x (7) Section IV. G - Maintaining Emergency Preparedness X I (8) Section IV. H - Recovery X I B. Effectiveness Determination For each applicable (i.e., a "yes" answer specified) standard to IOCFR50.47(b) and Appendix E to 10CFR50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement.

A facsimile of the evaluation form may be used as needed and attached to this checklist.

For applicable item 10CFR50.47(b)(1)(3)(8) and Appendix E,Section IV. A. C and E of Section A above, this change f DOES Z DOES NOT decrease the effectiveness of the Emergency Plan and Z DOES D DOES NOT continue to meet the stated applicable standard or requirement.

BASIS FOR ANSWER:

Added Mechanical Maintenance to the Repair & Corrective Actions section for the 60 min response. This was omitted during the last revision when Table 8.4 was added.

See attached for Frarnatome removaijustification.

Chemistry surveillance #5073 includes the actual use of the post-accident sampling systemu.i Therefore, it is not necessary to include actual sampling and risk exposure for an additional drill. Actual sampling will be credited during the surveillance and sampling during the drills will be simulated.

The Communications Assistant position was removed as the responsibilities are being performed by other members of the ERO. OP 3545 will have a figure depicting phones to be tested and it will be the responsibility of the EOF to complete this at the time of the room setup. Three part message forms can be picked up by the few individuals who still use them. All phones and radios that need to be manned are assigned per other appendices of this procedure. Establishment of radio communications is the responsibility of the Rad Coordinator and the radio operator. Recording the date, time, parties involved for each incoming/outgoing message is the responsibility of each of the other positions as defined in the other appendices.

VYAPF 3532.01 AP 3532 Rev. 11 Page 2 of 4

10 CFR 50.54(q) Evaluation Checklist (Continued)

The EOF Coordinator's Assistant position was removed and the responsibilities became part of the EOF Coordinator position.

This position was established prior to the E-Plan Duty Teams. The initial intent of the position was to be filled by whoever arrived first. They were to start setup and then inform the EOF Coordinator of any pertinent information upon his/her arrival.

Because the EOF Coordinator is part of an E-Plan Duty Team, the expectation is that he/she would arrive within an hour which would now be prior to the Assistant. The couple of tasks that the Assistant had to perform were assumed by the EOF Coordinator.

Conclusion (Fill out appropriate information)

The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50.

The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. The following course of action is recommended:

El Revise proposed changes to meet applicable standards and requirements.

El Cancel the proposed changes. ,

E. Process proposed changes for NRC approval prior to implementation in accordance with 10CFR50.54(q).

C. Impact on Other Documents (TRM, Tech Specs)

Keywords used in search:_

El This change does not affect any other documents.

3 This change does affect other documents.

- Doument(s) affected: EPIPs Section(s) affected:_ -

D. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required.

Keywords used in UFSAR search: does not affect UFSAR VYAPF 3532.01 AP 3532 Rev. 11 Page 3 of 4

10 CFR 50.54(q) Evaluation Checklist (Continued)

Additional Comments:

Prepared By: _AudraWilliams a4LtO(aL/W' Date: 4/12/04 (Print/Sign) U Reviewed By: ad z rd-&;2 < Date: 41l41oq (Emergency Plan Coordinator) (Print/Sigh)

VYAPF 3532.01 AP 3532 Rev. 11 Page4 of 4

To: File From: Lori A. Tkaczyk

Subject:

50-54(q) Justification for Removal of Framatome Services This assessment was undertaken to evaluate the role of the Framatome Engineering Support Center (ESC) within the Entergy Nuclear Vermont Yankee (ENVY) Emergency Plan,-and the need for the continued availability of the ESC to support station emergency responses. Comments from both ENVY and Framatome personnel, as well as Continuous Process Improvement (CPI) results, indicate that the ESC provides minimal value to the existing emergency response capabilities of the station.

This situation is due to several factors:

Framatome's routine support of ENVY has diminished over the years, and will likely be further reduced in the future. Many Framatome personnel with ENVY-related experience have left the firm. The emergency engineering (technical) support functions which were performed in the ESC were incorporated into the

'station's procedures.

Framatome also provides emergency response support at the Technical Support Center (TSC) (i.e., the Rad Advisor, Nuclear Safety Advisor, System Advisor),

the Emergency Operations Facility (EOF) (i.e., Rad Advisor, TLD Coordinator, Environmental Sample Coordinator) and the Westboro laboratory (i.e.,

environmental analysis). The personnel support for the TSC and EOF will be replaced by support from other Entergy resources. The laboratory services, which are not associated with the ESC, are not part of this assessment and will be retained. No resources are being deleted.

Historically, because Vermont Yankee did not have an on-site engineering organization, engineering and technical support was out-sourced and contracted through Yankee Nuclear Services Division (YNSD) to satisfy technical staffing requirements. The Engineering Support Center was established atYNSD to provide this support. Duke Engineering &Services (DE&S) assumed this role when they acquired YNSD. DE&S subsequently sold to Framatome ANP. The ESC is a legacy facility that adds little value to the station's current emergency response capabilities; the elimination of the ESC would not adversely affect these capabilities.

Vermont Yankee now has an on-site engineering organization. This Engineering Support Group is defined in the Plan. Drill and exercise experience has shown ENVY ERO personnel are fully capable of performing radiological assessment

and meteorology functions without support from Framatome. There are ERO personnel trained and qualified to perform radiological assessments assigned to the Control Room, TSC and EOF. These facilities possess the necessary radiological assessment software, and ready access to meteorological information. Should more detailed meteorological information or related expertise be required by the EOF, the National Weather Service can be contacted. There is no unique service or expertise that Framatome supplies in these areas.

Depending upon the emergency conditions and the response needs, the ENVY ERO can be augmented by manpower and equipment support arranged through the Institute of Nuclear Power Operations (INPO), as well as the Entergy White Plains Office and other members of the fleet.

Ifthe State of New Hampshire, State of Vermont, or Commonwealth of Massachusetts requests additional support staff or resources, INPO or ENVY White Plains can assist in meeting these requests through industry mutual assistance.

There is no regulatory requirement for the Engineering Support Center. The criteria for technical expertise and accident assessment are embedded into NUREG-0654 guidance, ll.B.8, "Each licensee shall specify the contractor and private organizations who may be requested to provide technical assistance to and augmentation of the emergency organization."

The input to the Implementation Plan was developed by analyzing the emergency support services provided by FRAMATOME and identifying the equivalents in place and any additional actions necessary to effect the change.

The mobile personnel TLD processing at the EOF, mobile whole body counter, the environmental sample analyses services provided by the Environmental Laboratory at Westboro, and, the use of the Alternate Joint News Center at Marlborough are retained. In addition, the supply and processing of TLDs for the states of MA and VT emergency workers are provided by the Environmental Lab.

These services are to be continued under a separate contract.

Memorandum DATE: April 13, 2004 TO: PORC FROM: Audra Williams, Emergency Plan On-Site Coord.

SUBJECT:

Emergency Plan Change #*4t'3 1hf7Iu' INTRODUCTION:

The latest revisions to the Emergency Plan are comprised of changes that do not decrease the effectiveness of the Plan which continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50. An AP 6002 Applicability Determination indicates that changes to the E-Plan are evaluated through the 50.54(q) process. A 10 CFR 50.54(q)

Evaluation Checklist is attached.

CHANGE

SUMMARY

• Table of Contents Removed the Mutual Assistance Agreement and replaced it with the Environmental Lab Analytical and Dosimetry Services portion that Framatome still provides per contract.

• Section 3.7, Technical Support Removed reference to Appendix D.

Section 7.1 Nuclear Alert System Added the new NAS system. Added that backup to NAS and Commercial phones is the satellite phone.

Section 7.7 Satellite Phones Added this section on the new satellite phones.

• Table 7.1 Vermont Yankee Emergency Communications Matrix Added the satellite phone locations to each of the ERFs.

Figure 7.1 Plant to Sate Notification Channels Added the satellite phone link.

• Figure 7.2 Coordination Channels with States Page 1 of 2

Extended the NAS line to include MA EOC.

Section 8.4.3 Additional Support Replaced the reference to the DE&S Mutual Assistance Agreement with the Corporate Support Center procedure.

• Table 8.4 Minimum Staffing Requirements for the ENVY ERO Added Mechanical Maintenance to the Repair & Corrective Actions section for the 60 min response.

• Figure 8.5 Emergency Operations Facility Organization Replaced the DE&S Mutual Asst Agreement with the Corporate Support Center

• Section 9.2.4 General Emergency Response Removed the EOF Coordinator's Asst and Communications Asst positions.

• Section 12.1.6 Health Physics Drills Removed the requirement that one drill include a PASS sample.

. Appendix.D Removed the DE&S Mutual Assistance Agreement and replaced it with the Environmental lab information.

Appendix E Letters of Agreement Replaced the annual INPO letter with the latest version.

Appendix G Index of Emergency Plan Implementing Procedures and Support Plans Removed the DE&S Mutual Assistance Agreement and replaced it with the Corporate Support Center Procedure.

Page 2 of 2

EMERGENCY PLAN I ENTERGY VERMONT YANKEE VERNON, VERMONT REVISION 39 PREPARER: Aiiwn WdIllotm. idha'lmt'- 3*2k'0$

Emergency Plan Coordinator (Print/Sign) Date 1

REVIEWED:

APPROVED:

K M~ovi. M. paul6 4.Uv~~f-.

lant 0 era*

k M4-v' Q60q-60q?

s Review Committee (Pri f/Sign) Date L/.q..o4 General Manager (Print/Sign) Date APPROVED: T V iAcWPrr Site tP iD Sie Vic Presi I PrtSn'De Effective Date 04/28/2004

ENTERGY VERMONT YANKEE EMERGENCY PLAN REVISION

SUMMARY

DATE REVISION'. DESCRIPTION 04/28/04 39 Replaced Framatome ANS services and the DE&S Mutual Assistance Agreement with the Corporate Service Center from White Plains. Updated information about the NAS to the new NAS system that was installed. Added Mechanical Maintenance to the Repair &

Corrective Actions section for the 60 min. response in Table 8-4.

Removed the EOFC Asst. and Communications positions. Removed requirement for drills to include a PASS sample.

Emergency Plan Revision 39 Revision Summary Page i of i Entergy Vermont Yankee

TABLE OF CONTENTS

1.0 INTRODUCTION

.......................... 1 2.0 DEFINITIONS ............ 2 3.0

SUMMARY

OF EMERGENCY PLAN ........................ 5 3.1. Objectives .................................. 5 3.2. Actions In An Emergency .................................. 6 3.3. Emergency Response Facilities .................................. 6 3.4. Mobilization .................................. 7 3.5. State Government Notification And Response ..................................  ; . 7 3.6. Federal Government Notification and Response .................................. 8 3.7. Technical Support ........................................ 8 4.0 THE AREA ...... 9 4.1. The Site ........................................ 9 4.2. Area Characteristics, Land Use and Demography ........................................ 9 4.3. Emergency Planning Zones ....................................... 10 5.0 EMERGENCY CLASSIFICATION SYSTEM . . ...........................23 5.1. Unusual Event ........................................ 23 5.1.1. Unusual Event (Terminated).............. ............ 23 5.2. Alert ...... 24 5.3. Site Area Emergency ................................................. 24 5.4. General Emergency .. 25 5.5. Emergency Classification System Review By State Authorities . .25 6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT . ..................................... 26 6.1. Emergency Response Facilities ..................... 26 6.1.1. Technical Support Center .................................. 26 6.1.2. The Operations Support Center .................................. 27 6.1.3. Emergency Operations Facility/Recovery Center ............................... 28 6.1.4. Deleted .................................. 29 6.1.5. Joint News Center ................................... 29 6.1.6.. Coordination of.Radiological Data ...................... 29 6.2. Assessment Capability ;....30 ....................

6.2.1. Process Monitors ............. 30 6.2.2. Radiological Monitors ............. 30 6.2.3. Meteorological Capability ................................ 31 6.2.4. Fire Detection Devices .32 6.2.5. Post-Accident Sampling .32 6.2.6. Facilities and Equipment for Offsite Monitoring .32 Emergency Plan Revision 39 Table of Contents Page i of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued) 7.0 COMMUNICATIONS ............................... 37 7.1. Nuclear Alert System .............................. 37 7.2. Utility Microwave and Radio Systems .............................. 37 7.3. Mobile UHF Radio System .............................. 38 7.4. Plant Intercom System ....................  ; 38 7.5. NRC Telephone System .....................  ; 38 7.6. Commercial Telephone System .39 7.7. Satellite Phones .39 7.8. Emergency Power Supply For Communications ................................. 39 7.9. Facsimile Transmission ................................. 39 7.10. Emergency Response Data System ............................. 39 8.0 ORGANIZATION ................................ 43 8.1. Normal Plant Organization ........................ 43 8.2. Emergency Response Organization ........................ 43 8.2.1. Site Recovery Manager ........................... 44 8.2.2. TSC Coordinator ........................... 45 8.2.3. Plant Emergency Director ........................... 47 8.2.4. EOF Coordinator ........................... 48 8.2.5. Operations Support Center Coordinator ........................... 49 8.2.6. Radiological Assistant ........................... 50 8.2.7. Radiological Coordinator ........................... 50 8.2.8. Purchasing Coordinator. .... ....... 51 8.2.9. Security Coordinator .;. . ... . . 52 8.2.10. Nuclear Information Director .52 8.2.11. Decision Maker .52 8.2.12. Engineering Support Group .53 8.3. Recovery Organization ......................................... 53 8.4. Extensions of Vermont Yankee Emergency Organization . .................................

54 8.4.1. Local Service ........................................ 54 8.4.2. Federal Government Support ........................................ 54 8.4.3. Additional Support ........................................ 55 8.5. Coordination With State Government Authorities . ..............................55 9.0 EMERGENCY RESPONSE . . . ............................70 9.1. Emergency Condition Recognition and Classification .............. ....................... 70 9.2. Activation of the Emergency Organization . . ...........................70 9.2.1. 'Unusual Event Response  ;..;;.........' 70 9.2.2. Alert Response .. 72 9.2.3. Site Area Emergency Response .. 73 9.2.4. General Emergency Response .. 74 9.3. Emergency De-Escalation and Termination Criteria . ................................... 74 Emergency Plan Revision 39 Table of Contents Page ii of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued) 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES ........................... 79 10.1. Radiological Assessment ............................................................ 79 10.1.1. Initial Offsite Radiological Dose Projection Capability ........................ 79 10.1.2. Variable Trajectory Atmospheric Dispersion/Dose Projection

10. Capability ...................  ; 80 10.1.3. Evaluation of Offsite Air'Samples ....... ............ 80 10.2. Protective Action Recommendation Criteria .81 10.3. Radiological Exposure Control .82 10.4. Protective Measures .82 10.4.1. Site Personnel Accountability .................................. 82 10.4.2. Site Egress Control Methods .................................. 83 10.4.3. Decontamination Capability .................................. 83 10.4.4. Use of Onsite Protective Equipment and Supplies ............................. 83 10.4.5. Fire Protection Equipment .................................. 83 10.5. Aid to Affected Personnel .. 84 10.5.1. Medical Treatment ................................................. 84 10.5.2. Medical Transportation ................................................. 84 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION . ..................................

92 11.1. Emergency Notifi6ation ................................................. 92 11.2. Public Notification ................................................. 92 11.3. Public Information ................................................. 93 12.0 MAINTAINING EMERGENCY PREPAREDNESS ....................................... 95 12.1. Drills and Exercises 95 12.1.1. Radiation Emergency Drills and Exercises .95 12.1.2. Communication Tests ................... 95 12.1.3. Fire Drills .96 12.1.4. Medical Drills .96 12.1.5. Radiological Monitoring Drills .96 12.1.6. Health Physics Drills .96 12.1.7. Scenarios .97 12.1.8. Evaluation of Exercises .98 12.1.9. Emergency Plan Audit .98 12.2. Training ........ 99 12.3. Review and Updating of Plan and Procedures .  ;.............................

.. 99

-12.4. Maintenance and Inventory of Emergency Equipment and Supplies .. ' 100 12.5. Responsibility for the Planning Effort ..............................  ;.;.;.;.100 Emergency Plan Revision 39 K) Table of Contents Page iii of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continsued)

APPENDICES Paae APPENDIX A Emergency Classification System and Emergency Action Levels 101 APPENDIX B Emergency Equipment 103 APPENDIX C Initial Offsite Dose Rate Estimation 106 IAPPENDIX D Environmental Laboratory Analytical and Dosimetry Services 108 APPENDIX E Letters of Agreement 111 APPENDIX F Evacuation Time Estimates 147 APPENDIX G Index of Emergency Plan Implementing Procedures and Support Plans 155 APPENDIX H Public Notification System .158 Emergency Plan Revision 39 Table of Contents Page iv of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued)

LIST OF TABLES Table 4.1 Table of Land Use Table 4.2 1990 Population Distribution Within the 50-Mile EPZ of Vermont Yankee Table 4.3 Vermont Yankee "Plume Exposure" Emergency Planning Zone (10 Mile)

Considerations Table 7.1 Vermont Yankee Emergency Communications Matrix Table 8.1 Emergency Organization Staffing Assignments Table 8.2 (Deleted)

Table 8.3 A Summary of Offsite Coordination Table 8.4 Minimum Staffing Requirements for the ENVY ERO Table 9.1 Vermont Yankee Emergency Response Table 10.1.1 ..EPA Protective Action Guidelines Table 10.1.2 Recommended Derived Intervention Level (DIL) or Criterion for Each Radionuclide Group Table 10.2 Emergency Dose Limits Table 10.3 Emergency Center Habitability and Protective Action Criteria Emergency Plan Revision 39 Table of Contents Page v of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued)

LIST OF FIGURES Figure 4.1 Vermont Yankee Site Figure 4.2 Population Center and Special Interest Areas Within the 50 Mile EPZ Figure 4.3 1990 Population Distribution Within 0-5 Miles of Vermont Yankee Figure 4.4 1990 Population Distribution Within 0-10 Miles of Vermont Yankee Figure 4.5 1990 Population Distribution Within 10-50 Miles of Vermont Yankee Figure 4.6 Sector Nomenclature for Vermont Yankee Plume Exposure EPZ Figure 4.7 Vermont Yankee Plume Exposure Emergency Planning Zone Figure 4.8 Vermont Yankee 50 Mile Ingestion Pathway Emergency Planning Zone Figure 6.1 Location of State and Company Emergency Operating Centers Around Vermont Yankee Figure 6.2 Technical Support Center Layout Figure 6.3 Operations Support Center Layout Figure 6.4 Emergency Operations Facility/Recovery Center Layout Figure 7.1 Plant to State Notification Channels Figure 7.2 Coordination Channels with States Figure 8.1 Normal On-Shift Emergency Organization Figure 8.2 Vermont Yankee Emergency Management Organization Figure8.3 ' Technical Support Center"Emergency Organization Figure 8.4 Operations Support Center Emergency Organization Figure 8.5 Emergency Operations Facility Organization Figure 8.6 (Deleted) l Figure 8.7 Joint News Center Organization Emergency Plan Revision 39 Table of Contents Page vi of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued)

LIST OF FIGURES (Continued)

Figure 9.1 Notification Plan Figure.10.1 . Vermont Yankee Emergency Dose Rate Nomogram Figure 10.2 Field Sample Thyroid Dose Nomogram Figure 10.3 Medical Facilities within 50 Miles of Vermont Yankee Capable Of Handling Emergency Medical Cases Emergency Plan Revision 39 Table of Contents Page vii of vii Entergy Vermont Yankee

1.0 INTRODUCTION

In the event of an emergency at the Vermont Yankee Nuclear Power Station, officials from Vermont Yankee, local towns, the states of Vermont, New Hampshire and Massachusetts, as well as federal assistance resources, are mobilized to assess conditions and protect the health and safety of the public. This document outlines the emergency response actions that are taken by Vermont Yankee and the manner in which this response interfaces with offsite response actions.

This Emergency Plan is only a part of the overall response to an emergency at Vermont Yankee. Each community within about a 10-mile radius of the plant and the states (Massachusetts, New Hampshire, and Vermont) have developed emergency response plans to be implemented if the need arises. In addition, federal agencies have specified their nuclear power plant emergency response roles and capabilities in the federal Radiological Emergency Response Plan.

The objective of this document is to outline the overall response of the Company to an emergency at the site. If an abnormal situation develops, automatic initiation of plant safety systems takes place and plant operators take corrective action according to specific emergency operating procedures. The purpose of these emergency operating procedures is to describe corrective actions necessary to restore normal plant safety margins. The emergency operating procedures also lead to the activation of the Emergency Plan in accordance with a prescribed set of emergency implementing procedures. The Emergency Plan summarizes Vermont Yankee's emergency implementing procedures and thereby the overall response to an emergency at the site.

Emergency Plan Revision 39 Page 1 of 166 Entergy Vermont Yankee

2.0 DEFINITIONS Alert - Indicates a substantial degradation of plant safety margins which could affect onsite personnel safety, could require offsite impact assessment, but is not likely to require offsite public protective action.

Assessment Actions - Those actions Which are take to effectively define the'emergency situation necessary for decisions on specific emergency measures.

Code Red - A Security related contingency requiring the activation of the Security Response Team. This contingency shall, as a minimum cause a Notice of Unusual Event to be announced.

Committed Dose Equivalent (CDE) - The dose equivalent to organs or tissues of reference (e.g., thyroid) that will be received from an intake of radioactive material by an individual during the 50 year period following the intake.

Corrective Actions - Those emergency measures taken to ameliorate or terminate an emergency situation.

Emergency Action Levels - Specific instrument readings, system or event observation and/or radiological levels which initiate event classification, notification procedures, protective actions, and/or mobilization of the emergency response organization. These are specific threshold readings or observations indicating system failures or abnormalities.

Emergency Assistance Personnel - Vermont Yankee personnel who are assigned a role in the Emergency Response Organization.

Emergency Classification - Emergencies are classified into four categories, UNUSUAL EVENT, ALERT, SITE AREA EMERGENCY and GENERAL EMERGENCY.

Emergency Implementing Procedure - Specific action taken by the plant staff to activate and implement this Emergency Plan.

Emergency Operations Centers - Areas designated by the statellocal representatives as Emergency Plan assembly areas for their respective staffs.

Emergency Operating Procedu'res -'The outline of specific corrective actions to be taken by plant operators in response to abnormal operating conditions.'

Emergency Plan Revision 39 Page 2 of 166 Entergy Vermont Yankee

Emergency Operations Facilitv - A center established to coordinate the deployment of emergency response personnel, to evaluate offsite accident conditions and to maintain communications with offsite authorities.

Emergency Planning Zone - The areas for which planning is recommended to assure that prompt and effective actions can be taken to protect the public in the event of an accident.

The two zones are the 10-mile radius plume exposure pathway zone and the 50-mile radius ingestion pathway zone.

Emergency Response Organization - Organization comprised of Emergency Assistance Personnel who would respond and assist in a classified emergency situation.

Engineering Support Group - An engineering group established to provide emergency support for plant assessment and recovery operations.

Gai-Tronics - An intra-site station operation and public address system which consists of speakers and microphones located in areas vital to the operation of the station. The system has four channels which provide separate and independent page and intercommunication capabilities.

General Emergency - A General Emergency involves substantial core degradation or melting with potential for loss of containment integrity.

Ingestion Exposure PathwaV - The pathway in which individuals receive a radiation dose due to internal deposition of radioactive materials from inigestion of contaminated water, foods, or milk.

Joint News Center - A center dedicated to the news media for the purpose of disseminating and coordinating information concerning accident conditions. Activities conducted within this center will be the responsibility of the Nuclear Information Director (Director of Public Affairs or designee).

Operations Support Center - An emergency center established for available skilled emergency personnel (i.e., additional operations and support personnel). The Operations Support Center Coordinator directs activities within this center.

Plume Exposure Pathway - The pathway in which individuals receive a radiation dose due to:

a) whole body external exposure due to gamma radiation from the plume and from deposited material; and b) inhalation exposure from the passing radioactive plume.

Proiected Dose - This is the amount of radiation does estimated at the onset of any accidental radiological release. Is includes all the radiation does the individual would receive for the duration of the release assuming that no protective measures were undertaken.

Emergency Plan Revision 39 Page 3 of 166 Entergy Vermont Yankee

Protective Action - Those emergency measures taken to effectively mitigate the consequences of an accident by minimizing the radiological exposure that would likely occur if such actions were not undertaken.

Protective Action Guides - Projected radiological dose values to the public which warrant protective actions following an uncontrolled release of radioactive materials. Protective actions would be warranted provided the reduction in the individual dose is not offset by excessive risks to individual safety in implementing such actions.

Recovery Actions - Those actions taken after the emergency has been controlled in order to restore safe plant conditions.

Recovery Center - An area established within the Emergency Operations facility for the purpose of planning recovery actions. The Site Recovery Manager directs the activities of this center.

Severe Accident Management - Process that management uses to evaluate and respond to an accident that has deteriorated to a condition where the EOPs are exited and the Severe Accident Guidelines are used.

Site - That property within the fenced boundary of Vermont Yankee which is owned by the Company.

Site Area Emergencv - a Site Area Emergency indicates an event which involves likely or actual major failure of plant functions needed for the protection of the public.

Technical Support Center - An in-plant center established in close proximity to the Control Room that has the capability to acquire plant parameters for post-accident evaluation by technical and recovery assistance personnel. The Technical Support Center Coordinator directs activities within this center.

Total Effective Dose Equivalent (TEDE) - The sum of the deep dose equivalent from external sources and the committed effective dose equivalent from internal exposures.

Unusual Event - An Unusual event indicates a potential degradation of plant safety margins which is not likely to affect personnel onsite or the public offsite or result in radioactive releases requiring offsite monitoring.

Unusual Event (Terminated) - A condition that warrants an Unusual event declaration, but was immediately rectified, such that the condition no longer existed by the time of declaration.

The event or condition did not affect personnel onsite or the public offsite, or result in radioactive releases requiring offsite monitoring.

Emergency Plan Revision 39 Page 4 of 166 Entergy Vermont Yankee

3.0

SUMMARY

OF EMERGENCY PLAN 3.1. Obiectives Safety systems at Vermont Yankee are designed to prevent and/or mitigate accidental radioactive releases. Accordingly, the probability for a release of radioactivity resulting in a public hazard is very small. As a precautionary measure, however, this Emergency Plan specifies response actions if the safety systems are degraded or fail.

The purpose of this Emergency Plan is to classify emergencies according to severity, to assign responsibilities, and to clearly outline the most effective actions to safeguard the public and plant personnel in the unlikely event of an incident at Vermont Yankee. Detailed emergency procedures at Vermont Yankee are followed by plant personnel to notify and activate the onsite and offsite emergency organizations. These procedures are summarized in this Emergency Plan.

The basic objectives of this plan are:

1) To establish a system for identification and classification of the emergency condition and initiation of response actions;

2) To establish an organization for the direction of activity within the plant to limit the consequences of the incident;

3) To establish an organization for control of onsite and offsite surveillance activities to assess the extent and significance of any uncontrolled release of radioactive material;

4) To identify facilities, equipment and supplies available for emergency use;

5) To establish an engineering support organization to aid the plant personnel in limiting the consequences of and recovery from an event;

6) To establish the basic elements of an emergency recovery program;

7) To specify a system for coordination with federal, state, and local authorities and agencies for offsite emergency response;

-.8) To develop a communications network between the plant and offsite authorities to

-provide prompt notification of emergency situations;  ::

9) To develop a training and Emergency Plan exercise program to assure constant effectiveness of the plan; and

10) To keep the public informed in a timely manner to preclude misinformation and bolster confidence in the emergency response.

Emergency Plan Revision 39 Page5of166 Entergy Vermont Yankee

Emergencies at nuclear power plants are classified into the following four major categories (as set forth in Section 5.0): Unusual Event, Alert, Site Area Emergency, and General Emergency.

Depending on the emergency classification, different levels of plant and offsite response are required. Activation of emergency facilities takes place in accordance with the classification of emergency response.

3.2. Actions In An Emergency If an emergency condition develops, the Shift Manager or the senior licensed individual in the Control Room, assumes the responsibilities of the Plant Emergency Director. This individual is responsible for initiating emergency actions to limit the consequences of the incident and to bring the plant into a stable condition. The individual must:

1) Recognize the emergency condition by observation of Emergency Action Levels;

2) Classify the accident in accordance with the emergency classification system;

3) Initiate emergency operating procedure(s) applicable to the event;

4) Activate the plant emergency alarm system;

5) Notify state authorities in Vermont, New Hampshire and Massachusetts using the Nuclear Alert System (Orange Phone);

6) Notify the NRC using the Emergency Notification System;

7) Use the plant pager system to notify appropriate personnel as set forth in Figure 9.1 and Table 9.1;

8) Depending on the emergency classification, initiate the procedures which activate the Technical Support Center, the Emergency Operations Facility/Recovery Center, the Operations Support Center, and the Joint News Center; and

9) Direct and coordinate all emergency response efforts until overall responsibility is assumed by the TSC Coordinator or the Site Recovery Manager.

3.3. Emergency Response Facilities The emergency response facilities, which are utilized by the emergency response.

organization, are described in Section 6.0. Depending on the emergency classification, different facilities are activated and utiliz6d. Key site and offsite personnel are quickly dispatched to these facilities to perform accident assessments, implement corrective actions, analyze accident data, and provide public information support.

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3.4. Mobilization The mobilization scheme is based on the emergency notification system shown in Figure 9.1.

Table 9.1 identifies the personnel notified. The notification system utilizes the plant public address system (Gai-Tronics), dedicated telephone lines, and radio pager devices (beepers) to notify and mobilize personnel. Key Vermont Yankee and support personnel carry radio pagers to expedite the mobilization process during off-hours. Depending upon the-emergency classification, different levels of mobilization are implemented. The mobilization scheme ensures that specific technical disciplines identified by Table B-1 of NUREG-0654 can be augmented within appropriate time frames. Table 8.4 outlines the minimum staffing requirements for the Emergency Response Organization at Vermont Yankee. Table 9.1 summarizes the response to the four classes of emergencies described in Section 5.0.

3.5. State Government Notification And Response Vermont Yankee's Emergency Plan interfaces with the state emergency response plans of Vermont, New Hampshire and Massachusetts. Local town governments, in coordination with the emergency management agencies of these states, have plans, which if the need arises, contain instructions to carry out specific protective measures dependent upon various emergency conditions.

Vermont Yankee is responsible for conveying specific accident information, radiological assessment information, and protective action recommendations to the State of Vermont, State of New Hampshire, and Commonwealth of Massachusetts. It is the responsibility of each respective state Department of Public Health to evaluate this information and make appropriate recommendation regarding public protective actions in accordance with their plans and procedures.

A cooperative arrangement exists among the Vermont, New Hampshire and Massachusetts State authorities and Vermont Yankee Nuclear Power Station concerning radiological emergency preparedness. Vermont Yankee's emergency classification system and notification messages are reviewed and approved by these states in accordance with the terms specified in the Letter of Agreement found in Appendix E. Each state is committed to dispatching representatives to the plant's Emergency Operations Facility/Recovery Center when conditions warrant. Vermont Yankee's Joint News Center provides the opportunity for joint utility, state and federal press briefings to be held.

.. .- ... - , .- s. .. . . . . .  : :

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3.6. Federal Government Wotification and Response As soon as an event is classified into one of the four categories of emergencies, notification to the NRC is made using the Emergency Notification System. Once notified of an emergency, the NRC evaluates the situation and determines the appropriate NRC response. Depending on the severity of the accident and the emergency classification declared, the NRC activates their incident response operations in accordance with the NRC Incident Response Plan. The NRC notifies the Federal Emergency Management Agency (FEMA) and other appropriate federal agencies to activate the federal emergency response organization in accordance with the Federal Radiological Emergency Response Plan (FRERP). The FRERP makes available the resources and capabilities of 12 federal agencies to support plant, state and local governments. Principal participants are the NRC, FEMA, Department of Energy (DOE), and Environmental Protection Agency (EPA).

3.7. Technical Support Technical and manpower support are provided to the Vermont Yankee plant through support plans listed in Appendix G. Support beyond this level is arranged through the Institute of Nuclear Power Operations (INPO).

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4.0 THE AREA 4.1. The Site Vermont Yankee Nuclear Power Station is located on the west bank of the Connecticut River immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. The Vermont Yankee Nuclear Power Station is a boiling water reactor having a thermal rated power of 1593 MWt and a gross electrical output of 550 MWe. The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Vermont Yankee, with the exception of a narrow strip of land between the Connecticut River and the Vermont Yankee property for which it has perpetual rights and easements from the owner, New England Power Company.

4.2. Area Characteristics, Land Use and Democraphy The site, also shown in Figure 4.1, is bounded by the Connecticut River (Vernon Pond) on the east, by farm and pasture land mixed with wooded areas on the north and south, and by the town of Vernon on the west. Warwick and Northfield State Forests (approximately 8 miles southwest of the site), Green Mountain National Forest (approximately 18 miles southwest of the site) and the Pisgah Mountain Range (northeast of the site) limit the population density and land use within a 50-mile radius of the site. Most of the land around the sire is undeveloped.

Table 4.1 characterizes the land use within 25 miles of the plant. The developed land is used for agricultural, dairying, and for residential areas within small villages. The primary agricultural crop is silage corn, which is stored for year-round feed for milk cows.

The nearest house is 1,300 feet from the Reactor Building and is one of several west of the site. The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500 feet from the Reactor Building. The nearest hospital, Brattleboro Memorial, is approximately five (5) miles north-northwest form the site. The nearest dairy farm is approximately 1/2-mile northwest of the site. Additional dairy farms are located within a 5-mile radius of the plant.

The largest sports facility in the vicinity is the Hinsdale Raceway, located approximately three (3) miles from the site. For racing events, the average attendance is approximately 4,000. A nursing home is located 2 miles south of the plant. These areas have been noted since they have required special planning consideration by offsite authorities in the event of a radiological emergency at Vermont Yankee.

Figure 4.2 shows an overall perspective of the area within 50 miles of Vermont Yankee. The average population density within a 10-mile radius of Vermont Yankee for 1990 was estimated to be 105 people per square mile. Figures 4.3, 4.4, and 4.5 provide the 1990 population distribution within a 5-, 10-, and 50-mile radius of the Vermont Yankee Nuclear Power Station.

Table 4.2 summarizes these data.

Emergency Plan Revision 39 Page 9 of 166 Entergy Vermont Yankee

4.3. Emergency Planning Zones The NRC/EPA Task Force Report on Emergency Planning, "Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light-Water Nuclear Power Plants" (NUREG-0396) established the size of planning zones for which predetermined emergency actions should be prepared. These planning zones were selected based upon the knowledge of the potential consequences, timing and release characteristics of a spectrum of accidents (including core melt scenarios), regardless of the low probability of occurrence. As a result, an Emergency Planning Zone concept was developed, both for short-term plume exposure and for the longer-term ingestion exposure pathways.

Emergency Planning Zones (EPZs) are defined as the areas for which planning is needed to assure that prompt and effective actions can be taken to protect the public in the event of an accident. The size of the Emergency Planning Zones represents the extent of detailed planning which should be performed to assure an adequate response. Dependent upon the severity of the accident, protective actions are generally limited to only portions of the designated EPZs, but as the need arises, actions are undertaken for the entire zones.

As a means of defining selected areas within the planning zones, Vermont Yankee divides the planning zones into sectors of 22 1/2 degrees centered on the 16 standard compass directions (see Figure 4.6). Each sector is identified by a letter ("I" and "O" are not used) and/or the standard compass direction. Distance from the plant is defined in terms of miles radially outward from the plant.

Vermont Yankee, for the purpose of radiological protection, is responsible for exercising direct control over the emergency activities within the exclusion area' shown in Figure 4.1. Means of controlling access on the river is the responsibility of the State of New Hampshire.

In accordance with the recommended planning bases, Vermont Yankee has expanded its previous planning considerations by defining two Emergency Planning Zones. The plume exposure EPZ, shown in Figure 4.7, is an area designated by the jurisdictional boundaries of those communities which are within a radial distance of 10 miles from the plant site. The size of the zone is based on the following considerations: 1) projected doses estimated for most accidents would not exceed the EPA Protective Action Guides outside the zone; 2) detailed planning within this area would provide a substantial base for expansion of response efforts in the event that it is necessary; 3) planning within this area recognizes all jurisdictional restraints imposed by the zone designation. Table 4.3 lists the local communities that are affected by this designation, the wind direction which would potentially affect these communities if a' release occurs, and the sector/distance identification representing each of these communities.

As specified in the state plans, communities within the plume exposure EPZ are alerted if a major accident at Vermont Yankee occurs. Communities within this zone have their own local radiological response plans.

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The ingestion exposure pathway Emergency Planning Zone, shown in Figure 4.8, is an area within a 50-mile radius from the plant site. The size of the zone is based on the fact that the downwind range within which significant contamination could occur would generally be limited to this distance because of wind shifts and travel periods. In addition, projected doses from contamination outside this zone would not exceed the Department of Health and Human Services' ingestion pathway Protective Action guides. Four states (Vermont, New Hampshire, Massachusetts, and New York) are responsible for coordinating and implementing protective actions within this area. Precautionary measures relative to livestock feeds, milk products, garden produce, and potable water supplies are implements in this area to the extent dictated by the release conditions.

i Emergency Plan Revision 39 Page 11 of 166 Entergy Vermont Yankee

TABLE 4.1 TABLE OF LAND USE (Square Miles)

Distance from Site Land Use 0-10 Miles 10-25 Miles 1-25 Miles Residential 30.2 79.2 109.4 Commercial and Industrial 1.3 7.7 9.0 Agricultural 25.9 143.8 169.7 Road 6.0 21.6 27.6 Public 7.2 78.3 85.5 Undeveloped 243.4 1318.4 1561.8 TOTAL 314.0 .1649.0. 1963.0 Emergency Plan Revision 39 Page 12 of 166 Entergy Vermont Yankee

TABLE 4.2 1990 POPULATION DISTRIBUTION WITHIN THE 50-MILE EPZ OF VERMONT YANKEE

-POPULATION TOTALS BY ZONE Ring Cumulative Miles Population Miles Population 0-1 454 0-1 454 1-2 2352 0-2 2806 2-3 1791 0-3 4597 3-4 1489 0-4 6086 4-5 3393 0-5 9479 5-10 23510 0-10 32989 10-20 104415 0-20 137404 20-30 136579 0-30 273983 30-40 324069 0-40 598052 40-50 837647 0-50 1435699 POPULATION TOTALS BY SECTOR Total Population Total Population Sector 0-50 Miles Sector 0-50 Miles A (N) 47248 J (S) 459545 B (NNE) 36206 K (SSMW 117432 C (NE) 41390 L (SW) 29807 D (ENE) 50258 M (WSW) 84396 E (E) 79304 N (A 42118

. .F P.

(ESE) 188056 (WNW) 32432 G (SE) - 133501 -. Q (NW) 15227 H (SSE) 59636 R (NNW) 19143 Emergency Plan Revision 39 Page 13 of 166 Entergy Vermont Yankee

TABLE 4.3 VERMONT YANKEE "PLUME EXPOSURE" EMERGENCY PLANNING ZONE (10 MILE) CONSIDERATIONS COMMUNITIES APPROPRIATE SECTOR Al,FECTED BY WINDS INVOLVED IDENTIFICATION* BLOWING FROM

1. Brattleboro, VT P (7-10), R and Q (4-10) ESE - S

2. Dummerston, VT Rand A (8-10) SE - SSW

3. Guilford, VT L (3-5), M, N and P (2-9), Q (3-6) NNE - SSE

4. Halifax, VT M (9-10), N and P (8-10) ENE - SE

5. Vernon, VT F (0-2), G and H (0-4), J (0-3), K and L (0-4), M, N, and P (0-3), Q and R (0-4) ALL DIRECTIONS

1. Chesterfield, NH A and B (5-10), C (6-10) SSE - WSW

2. Hinsdale, NH R, A, and B (0-6), C (0-4), D and E (0-3), F (1-4), G (2-5) ALL DIRECTIONS

3. Richmond, NH D,E,andF(9-10) WSW- WNW

4. Swanzey, NH

• C (8-1 0),.D (9-1 0) SSW-W

5. Winchester, NH R (6-8), A and B (5-10), C (6-10) S-NW

1. Bernardston, MA J (3-9), K (3-10), L (3-8) NNW- ENE

2. Colrain, MA L and M (9-10) NNE-E

3. Gill, MA H and J (7-10) NNW- NNE

4. Leyden, MA K (7-10), L and M (5-10) N- E

5. Northfield, MA G (4-10), H (3-10), J (3-7) WNW- NNE

6. Warwick, MA t and G (6-10) W- NNW

7. Greenfield, MA J and K (8-10) .N- NE..

• Numbers in parentheses represent approximate miles from plant.

Emergency Plan Revision 39 Page 14 of 166 Entergy Vermont Yankee

Figure 4.1

.I. . .Y Vermnont Yankee Site Emergency Plan Revision 39 Page 15 of 166 Entergy Vermont Yankee

v N

+UIQSPITAL A RUTLAND I.I

, ,g R)14,000 CNMRD 1,.>RESERVOIR

• _ LA t fVlA AlbanN BRAT/LEBOR0 RES I 1/ ~VT WGM-N J.8 GREeEL_ 1NORIFIEDIAS Emrgc PELn

/ _ RESERVOIR Ito CWCOPEE S WOCE1E6 P 9 16 DAM

_,_,,_,_MASS_ rPNF~ MASS_ ,_,

CONN. A t ON -R RES DAM WRevision 39 Figure 4.2 Population Center and Special Inte rest Areas Within the 50 Mile EPZ

'Emergency Plan

- . Revision 39 Page 16 of 166 tntergy vermont Yanvee

N ENE WNW (D)

(P)

E W

252 (E)

(N) 72

ESE

-(M) /.(F)

WSW Figure 4.3 1990 Population Distribution Within 0 -5 Miles of Vermont Yankee Emergency Plan Revision 39 Page 17 of 166 Entergy Vermont Yankee

N 14 (N W ......... ....

W .. .. .... . ... .

(N) 54 ..: .-. 2958 (E Figure 4.4 1990 Population Distribution Within 0 -10 Miles of Vermont Yankee Emergency Plan Revision 39 Page 18 of 166 Entergy Vermont Yankee

N ... . ..

ENE WNW (D)

(P) I E

W o (E) 1127 (N)

. 51 ESE (F)

-(M)\

. : I.

• -~WSW Figure 4.5 1990 Population Distribution Within 10 - 50 Miles of Vermont Yankee Emergency Plan Revision 39 Page 19 of 166 Entergy Vermont Yankee

348 3/4 N 11 114*

114 281

..... ,. - s 4*

25.34..... *..... ( )

WW\ (N) . (J /S -H (E 191 114- S 168374 NOTE: Each sector is 22%O2 and is designated by either a letter ("i" and "0" not used) or a standard compass direction identification.

Figure 4.6 Sector Nomenclature for Vermont Yankee.

• Plume Exposure EPZ Emergency Plan Revision 39 Page 20 of 166 Entergy Vermont Yankee

0 5 -lo . 15 Figure 4.7 Vermont Yankee Plume Exposure Emergency Planning Zone

• Only those portions of the communities that are within a 10-mile radius have been covered by the Public Notification System. All communities within this EPZ Boundary designation have developed an emergency plan.

Emergency Plan Revision 39 Page 21 of 166 Entergy Vermont Yankee

0 10 20 30 40 50 Miles Figure 4.8 Vermont Yankee 50 Mile Ingestion Pathway Emergency Planning Zone Emergency Plan

• Revision 39 Page 22 of 166 Entergy Vermont Yankee

5.0 EMERGENCY CLASSIFICATION SYSTEM The wide spectrum of component or system failures, or other occurrences that could potentially reduce plant safety margins, needs to be categorized. For this reason, a classification system has been defined which categorizes incidents according to severity into the following four classes: Unusual Event, Alert, Site Area Emergency, and General Emergency.

The incidents leading to each of the four emergency classifications are further identified by certain measurable and observable indicators of plant conditions called Emergency Action Levels (EALs) listed in Appendix A. Emergency Action Levels defined in Appendix A aid the operator in recognizing the potential of an incident immediately and assure that the first step in the emergency response is carried out. The classification of the event may change as the conditions change.

The VY EALS were derived from example initiating conditions in NUREG-0654, Rev. 1. The EAL bases are derived from NUMARC/NESP-007, Rev. 2.

5.1. Unusual Event AN UNUSUAL EVENT INDICATES A POTENTIAL DEGRADATION OF PLANT SAFETY MARGINS WHICH IS NOT LIKELY TO AFFECT PERSONNEL ONSITE OR THE PUBLIC OFFSITE OR RESULT IN RADIOACTIVE RELEASES REQUIRING OFFSITE MONITORING.

Unusual Event conditions do not cause serious damage'to the plant and may not require a change in operational status. The purpose of the Unusual Event declaration is to: 1) ensure that the first step in any response later found to be necessary has been carried out; 2) bring the operating staff to a state of readiness; and 3) ensure that appropriate offsite notifications have been made in the event that additional support is required.

See Appendix A for a complete list of Emergency Action Levels corresponding to an Unusual Event.

5.1.1. Unusual Event (Terminated)

If a condition that warrants an Unusual Event declaration has occurred, and was immediately rectified such that the condition no longer existed by the time of declaration, this Unusual Event classification' is referred to as an'Unusual Event (Terminated).

The event or condition did not affect personnel onsite or the public offsite, or result in radioactive releases requiring offsite monitoring.

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5.2. Alert AN ALERT INDICATES A SUBSTANTIAL DEGRADATION OF PLANT SAFETY MARGINS WHICH COULD AFFECT ONSITE PERSONNEL SAFETY, COULD REQUIRE OFFSITE IMPACT ASSESSMENT, BUT IS NOT LIKELY TO REQUIRE OFFSITE PUBLIC PROTECTIVE ACTION. ANY RELEASES EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS.

Plant response and offsite notifications associated with this event classification assure that sufficient emergency response personnel, both onsite and offsite, are mobilized and respond to event conditions. Actual releases of radioactivity which exceed Technical Specification limits may be involved, thus radiation monitoring and dose projection may be an integral portion of the emergency response required. Plant emergency response facilities are activated at this classification. Activation of the Joint News Center at this classification is optional.

See Appendix A for a complete list of Emergency Action Levels corresponding to an Alert.

5.3. Site Area Emergency A SITE AREA EMERGENCY INDICATES AN EVENT WHICH INVOLVES LIKELY OR ACTUAL MAJOR FAILURES OF PLANT FUNCTIONS NEEDED FOR THE PROTECTION OF THE PUBLIC. ANY RELEASES NOT EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS EXCEPT NEAR SITE BOUNDARY.

The events included in this category represent a potential for offsite releases which could impact the public to the extent that protective actions may be necessary. The purpose of the Site Area Emergency declaration is to: 1) ensure that all plant emergency response elements are mobilized; 2) ensure that monitoring teams have been dispatched, if needed; 3) ensure that in-plant protective measures have been taken; 4) provide for direct interface with offsite governmental response organizations; and 5) provide updates for the public through offsite officials.

See Appendix A for a complete list of Emergency Action Levels corresponding to Site Area Emergency.

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5.4. General Emergency A GENERAL EMERGENCY INVOLVES SUBSTANTIAL CORE DEGRADATION OR MELTING WITH POTENTIAL FOR LOSS OF CONTAINMENT INTEGRITY. RELEASES CAN BE REASONABLY EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS OFFSITE FOR MORE THAN THE IMMEDIATE SITE AREA.

The purpose of the General Emergency declaration is to: 1) ensure that appropriate offsite officials are adequately advised as to the extent of plant degradation; 2) provide consultation with offsite authorities in establishing appropriate protective actions for the public; 3) provide updates for the public through offsite authorities; and 4) ensure that all emergency response organizations and resources are being applied to accident mitigation.

See Appendix A for a complete list of Emergency Action Levels corresponding to a General Emergency.

5.5. Emergency Classification System Review By State Authorities The emergency classification system specified above, as well as the EALs presented in Appendix A, are reviewed and concurred with the state authorities of Vermont, New Hampshire, and Massachusetts.

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6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT -

Following the declaration of an emergency, the activities of the emergency response organization are coordinated in a number of emergency response facilities. Figure 4.1 shows the relative locations of Vermont Yankee's onsite emergency response facilities. Figure 6.1 represents the locations of the offsite support organizations' Emergency Operations Centers relative to Vermont Yankee. Descriptions of Vermont Yankee facilities and assessment capabilities are presented below.

6.1. Emergency Response Facilities The emergency response organization is activated, in part or wholly, dependent upon the operating crew's recognition of Emergency Action Levels (EALs) which represent a particular emergency condition.. Facility activation may be modified or suspended if the safety of personnel may be jeopardized by a security event or other event hazardous to personnel.

Classification and subsequent declaration of the appropriate emergency condition by the Shift Manager transforms the Control Room complex into an emergency control center. Initially, the Control Room crew coordinates all phases of emergency response and corrective action required to restore the plant to a safe condition. The Control Room staffs attention focuses on regaining plant control as emergency response personnel report and are delegated emergency functions. The following describe each emergency response facility location.

6.1.1. Technical Support Center A Technical Support Center (TSC) has been established to direct post-accident evaluation and assist in recovery operations of the plant. The TSC is located on'the second floor of the Administration Building in close proximity to the Control Room and is radiologically habitable to the same degree as the Control Room for postulated accident conditions. This center is established under the supervision of the TSC Coordinator (i.e., the General Manager or a designated alternate), and staffed by members of the TSC organization shown in Figure 8.3. A portion of the TSC, as shown in Figure 6.2, is assigned for NRC Incident Response Team members who may be dispatched to the plant. The TSC has the capability to monitor various plant parameters needed to evaluate accident conditions by accessing the plant process computer and using the diagnostic capability that its staff offers. The TSC staff can access more computer capabilities through the support plans listed in Appendix G.

At maximum capacity, the center accommodates more than 25 personnel, but communications with the Enrgineering Sup"port Group reduces the necessity for a large number of technical support personnel at the TSC.

Emergency Plan Revision 39 Page 26 of 166 Entergy Vermont Yankee

Upon activation, the TSC provides the main communication link between the plant, the Control Room, the NRC, the Emergency Operations Facility/Recovery Center and the Engineering K> Support Group. Details of this communications capability are described in Section 7.0. The plant print files are located within the TSC boundary, and contain pending and as-built system and equipment drawings, system flow diagrams, isometrics, cable/wiring diagrams, equipment outline drawings, UFSAR, Emergency Plan and plant procedures.

The'TSC is activated by the TSC'Coordinator when a plant'condition exists which requires ongoing technical evaluation (i.e., Alert, Site Area or General Emergency conditions). The TSC may be activated by the TSC Coordinator under an Unusual Event if conditions warrant such an action. The TSC has the capability to assess radiological conditions. This assessment capability consists of monitoring for direct radiation and airborne particulates, and sampling and analysis for airborne radiolodine. Appendix B lists emergency equipment found in the TSC.

If staffing of the TSC is not possible due to a security event or other hazardous conditions, ERO personnel will be notified to report to an alternate location.

The TSC is deactivated by the Site Recovery Manager or the TSC Coordinator, depending on the emergency class, when the plant conditions have stabilized such that continuous technical assessment is no longer required.

6.1.2. The Operations Support Center The Operations Support Center (OSC), which'is located on the first floor of the Administration.

) Building, provides a general assembly area for Chemistry, Radiation Protection; Maintenance, Operations, and I&C Personnel (see Figure 6.3). It is staffed with sufficient in-plant personnel required to effect protective and corrective actions in support of the emergency situation. An Operations Support Center Coordinator directs the activities of this center from either the TSC or the OSC. In-plant phone extensions and a page/intercom system provide communication capability at the OSC. Emergency equipment listed in Appendix B has been provided with additional back-up capability provided at the Radiation Protection control point. If conditions warrant evacuation of this center, the Emergency Operations Facility/Recovery Center assumes OSC functions. The OSC remains active and staffed until terminated by the TSC Coordinator.

If staffing of the OSC is not possible due to a security event or other hazardous conditions, ERO personnel will be notified to report to an alternate location.

K) Emergency Plan Revision 39 Page 27 of 166 Entergy Vermont Yankee

6.1.3. Emergency Operations Facility/Recovery Center The Emergency Operations Facility/Recovery Center (EOF/RC) is located at the Vermont Yankee Training Center on Old Ferry Road in Brattleboro, Vermont, approximately 8.75 miles from the plant site (See Figure 6.1). The EOF has a radiation protection factor of 5 and a ventilation system equipped with HEPA filters which can be isolated. The Commission has approved this as the primary facility with no backup up EOF necessary.- (NW 84-44, February 27, 1984) The overall responsibility for the functions performed in the EOF/RC belongs to the Site Recovery Manager.

The Site Recovery Manager acts as the principal spokesperson for Vermont Yankee concerning all issues where an interface with offsite government authorities is required. The EOF Coordinator is responsible for continuous evaluation of all licensee activities related to an emergency having, or potentially having, environmental radiological consequences. The EOF/RC has sufficient space and design to accommodate the emergency response organization and responding representatives from government and industry who are responsible for limiting offsite consequences (see Figure 6.4). The EOF/RC provides information needed by federal, state, and local authorities for implementation of their offsite Emergency Plans, and a centralized meeting location for key representatives from the agencies.

The EOF/RC maintains extensive communications capability with all emergency response facilities. Section 7.0 details the extent of this capability. Site access and control, dose assessment, sample analysis, decontamination, and recovery planning activities are directed from various locations within the EOF/RC. The EOF/RC serves as the primary evacuation, re-assembly, and off-duty augmentation personnel assembly point. Public information statements concerning the plant emergency status are transmitted from the EOF/RC to the Joint News Center for release to the public.

The following copies of emergency planning documents are available in the EOF/RC:

• Site Emergency Plan and Implementing Procedures

• Area Maps

• State and Local Emergency Plans

• UFSAR Emergency equipment and supplies are maintained at the EOF/RC, including equipment necessary to assess radiological habitability. This consists of monitoring for direct radiation and sarripling and analysis for airborne radioparticulates and radioiodine!' For a list of EOF/RC emergency equipment, see Appendix B.

Emergency Plan Revision 39 Page 28 of 166 Entergy Vermont Yankee

6.1.4. Deleted K> 6.1.5. Joint News Center The Joint News Center (JNC) provides a centralized location for conducting joint state, federal and Vermont Yankee emergency news briefings in a manner to avoid hampering ongoing emergency response proceedings. It is expected that state and federal public information personnel will operate from the JNC.

The initial designated location of the JNC is the Vermont Yankee Training Center located in Brattleboro, Vermont. Ifaccident conditions (plume trajectory) jeopardize the habitability of this facility, the alternate JNC in Marlborough, Massachusetts would be utilized.

At the JNC,'the Nuclear Information Director (who is Vermont Yankee's Director of Public Affairs or designee) coordinates the generation and issuance of press releases concerning plant emergency conditions to the media. Prior to their release to the media, the Site Recovery Manager or designee approves releases.

The JNC will be activated upon an emergency classification of Site Area Emergency or higher except as noted below.

Activation of the JNC is optional prior to a Site Area Emergency and is dependent on the escalation of the event and/or public interest. Prior to the activation of the JNC, the Director of Public Affairs or designee would be coordinating press releases from his/her routine operations location.

6.1.6. Coordination of Radiological Data Centralized coordination of the offsite radiological assessment effort with all organizations interested in and/or performing assessments is of importance to ensure that the data and its interpretation are reviewed by all parties. The number and type of organizations performing this effort vary with time and following accident declaration and offsite notification. Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF/RC. State authorities join the EOF/RC monitoring and assessment activities. Federal response agencies would augment plant and state radiological assessment efforts upon their arrival.

Plant and state monitoring efforts are coordinated at the EOF/RC. All samples are screened for activity levels in the field. Positive results require additional analysis at the EOF/RC.

Analysis is completed in two phases. Initially, the sanr'ple is evaluated for radioiodine concentration levels using gamma energy analyses instrumentation. Having completed this analysis, total isotopic determination of activity levels is conducted using a GE(Li) system. The EOF/RC sampling capability is greatly enhanced by coordinating sample transfer and analysis with the Environmental Laboratory.

Emergency Plan Revision 39 Page 29 of 166 Entergy Vermont Yankee

When federal resources respond, a more suitable location than the EOF/RC may be needed.

As stated by the Department of Energy (DOE), the agency charged with the lead of the federal offsite monitoring resources, this effort would be established at some location in the general vicinity of the plant site that was adequate for the equipment and manpower deployed.

Arrangements will be made for such a location with DOE and the states when it is required.

Wherever this function is located, the basic objective is to assure monitoring efforts from all organizations are coordinated.

6.2. Assessment Capability The activation of the Emergency Plan and the continued assessment of accident conditions require extensive monitoring and assessment capabilities. The essential monitoring systems needed for recognition of abnormal events by the plant operators are incorporated in the Emergency Action Levels specified in Appendix A. This section briefly describes monitoring systems as well as other assessment capabilities.

6.2.1. Process Monitors Plant process monitors capability includes indications provided from various monitors located throughout the plant systems. Parameters monitored include pressure, temperature, flow, and equipment operating status. Vermont Yankee has also augmented these monitoring systems with the instrumentation to detect inadequate core cooling.

The manner in which process monitors are used for accident recognition and classification is given in the detailed Emergency Action Level listings in Appendix A.

6.2.2. Radiological Monitors A number of radiation monitors and monitoring systems are provided on process and effluent liquid and gaseous lines that serve directly or indirectly as discharge route for radioactive materials. These monitors, which include Control Room readout and alarm functions, exist in order that appropriate action can be initiated to limit fuel damage and/or contain radioactive material.

These monitors include:

1. Main steam line radiation monitoring system,

2. Air ejector off-gas radiation monitoring system,

- 3. Process and liquid effluent radiation monitors,

4. Containment atmosphere radiation monitoring system,

5. Reactor Building ventilation radiation monitoring system, and

6. Plant stack radiation monitoring system.

Specific details on these monitoring systems such as location, type, etc., are contained in the plant Updated Final Safety Analysis Report (UFSAR).

Emergency Plan Revision 39 Page 30 of 166 Entergy Vermont Yankee

In addition to installed monitoring systems, Vermont Yankee has augmented onsite radiological assessment capability to include high-range containment and stack radiation monitoring; improved in-plant iodine detection capability; and arrangements for containment atmosphere and reactor water samples.

6.2.3. Meteorological Capability Vermont Yankee maintains a 305-foot primary meteorological tower from which the following parameters are measured:

Wind speed at the 35 and 297 foot levels, Wind direction at the 35 and 297 foot levels, Ambierit temperature at the 35 foot level, and Vertical temperature difference between the 35 and 200-foot levels and the 35 and 297 foot levels.

In addition, precipitation and barometric pressure are measured on the ground.

Fifteen-minute averages of the meteorological data are automatically displayed in the Control Room and the EOF/RC. These meteorological data are used to calculate offsite dispersion parameters on a real-time basis at the EOF/RC during accident conditions.

Vermont Yankee also maintains onsite a 140 foot back-up meteorological tower from which the following parameters are measured:

• Wind speed at the 100 foot level,

• Wind direction at the 100 foot level, and

• Vertical temperature difference between the 33 - and 135-foot levels.

This tower serves as a back-up to the primary tower should it fail. The meteorological data from the back-up tower are displayed on video graphic recorders located in the Control Room.

In addition, Vermont Yankee has the capability to access additional meteorological information through offsite support services. This information can be forwarded to VY dose assessment personnel upon request.

Emergency Plan Revision 39 Page 31 of 166 Entergy Vermont Yankee

6.2.4. Fire Detection Devices Vermont Yankee has an extensive fire detection network which utilizes a combination of smoke detectors, thermal detectors, infrared detectors, ultraviolet detectors, and "rate of rise" detectors, as well as fire system status alarms as a means of providing plant operators with complete fire status information. This system is described in PP 7011, Vermont Yankee Fire Protection and Appendix R Program.

These detection systems, in addition to providing alarm indications in the Control Room, activate automatic fire suppression systems in certain vital areas within the plant.

Supplementing these systems are dry chemical and CO 2 extinguishers, standpipe systems, and a continuously available fire brigade.

6.2.5. Post-Accident Sampling Post-accident sampling capability provides for emergency sample collection of containment atmosphere, plant stack halogen and particulate components, and primary coolant.

Management implements radiological precautions to limit whole body exposure to 5 rem/individual for sampling and analyses conducted using these systems.

6.2.6. Facilities and Equipment for Offsite Monitoring States Emergency Management and/or the system load dispatcher provides reports concerning natural occurrences or severe weather conditions that may affect the plant area.

Offsite fire departments of Vernon and Brattleboro notify the plant of any fire which might have an impact on the plant. Local Law Enforcement Agencies notify Plant Security of any-situation in the area which might have an impact on the plant.

In addition to offsite monitoring equipment at the EOF/RC, Vermont Yankee maintains an offsite environmental monitoring program. Radiological environmental monitoring stations for the site and surrounding area monitor the environment under normal and accident conditions.

Radiological environmental monitoring stations have been established in accordance with Technical Specification (Technical Requirements Manual) requirements.

Vermont Yankee has full access to the services of the Environmental Lab in Westboro, Massachusetts which provides 24-hour service for emergency environmental samples and personnel dosimetry analysis. The Environmental Lab provides mobile equipment as detailed in Appendix D. The capabilities of the Westboro Environmental Lab constitute a full spectrum of analytical radioassay measurements on environmental sample media..A full'service TLD processing capability also exists at the Lab. p m Af e Additional offsite monitoring equipment and capability can be provided by federal agencies in accordance with the Federal Radiological Emergency Response Plan. As discussed in Section 6.1.6, this additional capability is integrated into existing efforts.

Emergency Plan Revision 39 Page 32 of 166 Entergy Vermont Yankee

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'TOLLAND WN'HA R 0 10 20 30 40 50 Miles Figure 6.1 Location of State and Company Emergency Operating Centers around Vermont Yankee Emergency Plan Revision 39 Page 33 of 166 Entergy Vermont Yankee

Figure 6.2 Technical Support Center Layout Emergency Plan Revision 39 Page 34 of 166 Entergy Vermont Yankee

CLEAN CHEM LAB-Y-I -~~7 Figure 6.3 Operations Support Center Layout Emergency Plan Revision 39 Page 35 of 166 Entergy Vermont Yankee

-I SSWITCHBOARD TELEPHONE EQUIPMENT ROOM ENGINEERING SUPPORT GROUP IRAD 1

REO RECOVERY C SRMASSESS-I OC PLANNING SMMENT CONFERENCE IOSMT AREA l BRIEFING AREA COMMUNICATION CONTROL LAB ,

PURCHASING IS

• VSTATE STATE z NRC ROOM ASSEMBLY o

.. WOMEN llMEN DECON N _ _ _ _ _ _ _ _ _ AREA Figure 6.4 Emergency Operations Facility/Recovery Center Layout Emergency Plan Revision 39 Page 36 of 166 Entergy Vermont Yankee

7.0 COMMUNICATIONS Ku The plant staff has available various means of communication systems for effective communications and coordination with offsite and onsite response organizations and/or teams.

A summary of the communication systems is defined in the communication matrix provided in Table 7.1 and outlined below.

7.1. Nuclear Alert System The Nuclear Alert System (NAS), originating in the Control Room, is a system of dedicated phone circuits independent of the normal land line phone system. The NAS is used to notify the State Police of Vermont, Massachusetts, and New Hampshire of any emergency. This system is a secure (dedicated) communications arrangement and is installed for' the primary purpose of initial notification of the States, via State Police, by the plant operators.

This system is manned on a 24-hour basis on both ends - the Control Room and the State Police dispatching points. The activation of the public notification system starts with this 24-hour State police link. NAS is tested monthly between the plant and the State Police agencies.

The Nuclear Alert System also links the Control Room, the Emergency Operating Centers and Incident Field Offices of Massachusetts, New Hampshire, and Vermont, and the Emergency Operations Facility/Recovery Center (EOF/RC). This communication system incorporates all the principal emergency response centers into a single dedicated network. The Nuclear Alert System network is shown in Figure'7.1 (Control Room Link) and in Figure 7.2 (EOF/RC Link).

Backups to the NAS phone system are the commercial phone system and satellite phones.

7.2. Utility Microwave and Radio Systems The Utility Microwave and Radio Systems are located in the Control Room. The Utility Microwave is a line-of-sight dedicated Avaya System used to notify system load dispatchers of emergency conditions at the plant. The telephone has buttons marked for each load dispatcher. By pushing one of the buttons on the telephone, it rings automatically at the selected location. In the event that communications fail with the NRC due to loss of the commercial telephone system, the load dispatchers are advised that Vermont Yankee will use the Utility Microwave System to provide updates of plant conditions to NRC Region I.

The Utility Radio Net is used as an alternate means of notifying load dispatchers. Load dispatchers have 24-hour manning capability at their organizations. The systems are tested once a week with both organizations.

Emergency Plan K) Revision 39 Page 37 of 166 Entergy Vermont Yankee

7.3. Mobile UHF Radio Svstem The Mobile UHF Radio System is utilized as a primary means of communications for offsite monitoring teams and security personnel; it is the alternate means of communications between the EOF/RC, the Control Room, TSC, and onsite response teams. The System consists of 100-watt UHF repeaters with high gain antennas mounted on top of the station meteorological towers. These repeaters are activated by any of the six base radio stations located in the Control Room, Secondary Alarm System (SAS), TSC, Security Gate I and CAS, and the EOF/RC. Also, the portable units activate the repeater. In the event the repeater fails, a "talk around" feature allows continued communications between portable units. This system is tested daily through operational use of the system.

Security also has the capability to contact via radio the Windham County Sheriff Dispatcher and any Vermont State Police Patrol Vehicle(s) located in close proximity to the plant.

7.4. Plant Intercom System The Intercom System (Gai-Tronics) is located in many areas throughout the plant, including the Control Room, Technical Support Center, Operations Support Center and Security Gates 1 and 2. This system consists of four channels and is utilized as a paging system during normal operations. During emergency situations, the system is used as the primary means for: (1) notifying plant personnel of the emergency, (2) coordinating the activities of onsite response teams with the Technical Support Center; (3) coordinating activities between Control Room and the Technical Support Center; (4) calling for any missing or unaccounted for personnel that may be in the plant; and (5) communicating between the plant emergency response facilities. This system is in continuous daily use.

7.5. NRC Telephone System The NRC has utilized the Federal Telecommunications System (FTS) telephone network for its.

emergency telecommunications system. The FTS system provides a separate (public cannot access) government telephone network which avoid potential public telephone blockage which may occur in the event of a major emergency.

The Emergency Notification System (ENS) utilizes an FTS line which exists between the NRC Operations Office in Rockville, Maryland and the Control Room, with extensions in the Communications Room and the NRC Room (NRC Resident Inspector's Office) of the Technical Support Center. This line is tested daily by the NRC and has a 24-hour manning capability at both organizations.

The Emergency Notification System (ENS) also utilizes a separate FTS line between the NRC Operations Office in Rockville, Maryland and the Site Recovery Manager's Office in the EOF/RC, with an extension in the Recovery Planning Area.

The Health Physics Network (HPN) which utilizes separate FTS lines from the TSC and EOF/RC, allows Vermont Yankee to transmit health physics and environmental information to the NRC through the Operations Center in Rockville, Maryland in a radiological event.

Emergency Plan Revision 39 Page 38 of 166 Entergy Vermont Yankee

7.6. Commercial Telenhone Svstem The commercial telephone system is used as a primary and alternate means of communications for notification and coordination. For conditions involving telephone company equipment blockage in the local area, alternate external telephone line arrangements have been made available to the plant.

7.7. Satellite Phones Hand held satellite phones are available in the Control Room, Technical Support Center and the Emergency Operations Facility/Recovery Center for use if the NAS and commercial phone systems are inoperable. The satellite phones can be used to call other satellite phones, commercial land line phones and cellular phones 7.8. Emergency Power Supplv For Communications Currently there are several telephone and other emergency communication channels (Gai-Tronics, radio network, and microwave) located within the plant that are connected to an emergency or redundant power supply. All emergency communications (including all phones) located within the plant are connected to an emergency or redundant supply.

There are power fail phones located in the EOF/RC, TSC, and Control Room, which will automatically activate if power is lost to the internal telephone system.

7.9. Facsimile Transmission High speed, quality facsimile equipment is located at the Technical Support Center (TSC),

Operations Support Center (OSC), Emergency Operations/Recovery Center, Joint News Center (JNC), and each respective state's Emergency Operation Center (EOC). This is used to transmit pertinent data and information concerning the emergency among these facilities.

7.10. Emergency Response Data System The Emergency Response Data System (ERDS) is a direct real-time electronic transmission of the following types of parameters to the NRC to assist them in monitoring the status of an emergency:

. Core and coolant system data,

. -Containment building data, .  :

. Radioactivity release data, and

• Site meteorological data.

Vermont Yankee activates the ERDS to begin transmission to the NRC Operations Center during an emergency which has been classified at an Alert or greater level.

Emergency Plan Revision 39.

Page 39 of 166 Entergy Vermont Yankee

TABLE 7.1 VERMONT YANKEE EMERGENCY COMMUNICATIONS MATRIX CALLING FROI A

'.CALLING

- TO CR TSC . OSC EOF JNC Technical Support Center (TSC) 1, 4, 5, 7 11 Operations Support Center (OSC) 1,7 1,7 Emergency Operations Facility (EOF) 1, 2, 4,11 1,4,10,11 1 Joint News Center (JNC) 1 1,10 1,10 Offsite and Site Boundary Monitors 1, 4 1,4 1,4 1 Nuclear Regulatory Commission 1, 5 1, 5, 6 1 1,5,6 1 State Police (VT, NH, MA) 1,2,11 1, 11 1 1,2,11 1 State EOCs (VT, NH, MA) 1, 2, 9,11 1, 11 1,2,9, 10, 11 1 Vermont Yankee Plant Security 1, 4, 7 1,4, 7 1, 7 1,4,7 Vermont Yankee Emergency Response Personnel ' 1, 8. . 1, '8 - ,'8 1,8 1, 8 KEY 1 Commercial Telephone System 2 Nuclear Alert System 3 Utility Microwave 4 Mobile UHF Radio System 5 Emergency Notification System I 6 Health Physics Network 7 Gai-Tronics 8 Personnel-Pager"System.

• 9 .'

Tri-State/Southwest .Fire'.Radio.

10 Facsimile Transmission 11 Satellite Phones Emergency Plan Revision 39 Page 40 of 166 Entergy Vermont Yankee

NOTES:6

1. SEE STATE RESPONSE PLAN FOR COMMUNICATION CHANNELS BETWEEN STATE POLICE AND STATE AGENCIES AND LOCALS. .OVERNOR

2. SEE STATE RESPONSE PLAN FOR LOCALS AND OTHER STATE AGENCIES TO BE NOTIFIED.

ONT

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.*FEDERALAGENCES i OCL I /SPONSE (i) I SATE PHONEKTONE AMPS2E NOTE 1

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Figure 7.1 Plant to State Notification Channels Emergency Plan

- Revision 39 uPage 41 of 166 Entergy Vermont Yankee

( C c NOTE:

1. SEE STATE RESPONSE PLANS FOR COMMUNICATION CHANNELS BETWEEN STATE EOCS AND FWD EOCS.

2. SEE STATE RESPONSE PLAN FOR LOCALS AND OTHER STATE AGENCIES TO BE NOTIFIED.  :

I NUCLEA LERTASYSTEM

- - - RADIO (STATE) -

Figure 7.2 Coordination Channels with States Emergency Plan Revision 39 Page 42 of 166 Entergy Vermont Yankee

8.0 ORGANIZATION This section describes how the normal plant and engineering support organization transform into an emergency response organization to effectively deal with any incident at Vermont Yankee.

8.1. Normal Plant Organization Vermont Yankee's normal operation and management organization consist of the onsite facility organization supported by the engineering and management organizations located offsite. The relationship and content of these onsite and offsite organizations are specified in the plant Technical Specifications, Technical Requirements Manual or Vermont Operational Quality Assurance Manual.

During normal operations, the minimum staff on duty at the plant during all shifts consists of one (1) Shift Manager, one (1) Control Room Supervisor, two (2) Control Room Operators, three (3) Auxiliary Operators, one (1) Shift Technical Advisor, one (1) Radiation Protection Technician, one (1) Chemistry Technician, and security personnel as indicated in Figure 8.1.

The responsibility for determining the status of the plant in an emergency is assigned to the Shift Manager, or in his absence from the Control Room, to the Control Room Supervisor who has the authority and responsibility to immediately initiate any emergency actions, including emergency classification and notification. In addition, a Duty on Call Officer is available on an on-call basis to respond to plant emergencies and can assume the role of the TSC Coordinator (a minimum requirement is a Plant Certification). Corrective action repair, as outlined in Table 8.4, is performed by Operations staff on-shift until supplemented by additional ERO staff.

8.2. Emergency Response Organization The Vermont Yankee emergency response organization is activated in part or in whole, depending upon the condition classification determined by the normal plant operations crew in the Control Room. Vermont Yankee's emergency response organization is divided into onsite and offsite elements. The Vermont Yankee Emergency Management Organization is shown in Figure 8.2. Staffing for the onsite emergency response facilities is shown in Figure 8.3 (Technical Support Center) and Figure 8.4 (Operations Support Center). Staffing for the off-site emergency response facilities is shown in Figure 8.5 (Emergency Operations Facility/Recovery Center). All or portions of these organizations are activated depending upon the emergency classification.

Elements of the emergency response plan are activated subsequent to an emergency declaration by the Plant Emergency Director; designated company personnel are notified and will report to designated locations. The emergency response action of the personnel already present are performed on a priority basis depending on the emergency conditions and the immediate need which those conditions dictate as determined by the onshift operations crew.

The specific priorities facing the emergency response forces in the various locations cannot be pre-established. They would be specific to the nature of the emergency and variable with time as it proceeds.

Emergency Plan Revision 39 Page 43 of 166 Entergy Vermont Yankee

Plans and procedures have been put into place to ensure the timely activation of emergency response facilities. Although the response time will vary due to factors such as weather and K> traffic conditions, a goal of sixty (60) minutes for activation has been established for onsite emergency facilities including the EOF.

For this reason, the coordinators and managers in the emergency response facilities are charged with the responsibility of determining the priority of response functions when initially activated and assembled, and ensuring that the needed functions be performed on the basis of the priority determination. This process of prioritizing needs and addressing them accordingly is specified in the Emergency Plan's implementing procedures.

In emergency situations, the Shift Manager/Plant Emergency Director, TSC Coordinator, or OSC Coordinator can authorize actions, without following the complete work order process, if these actions prevent the following:

Loss of important equipment, Personnel injury, or

• Plant trip.

The TSC and OSC Coordinators are responsible for updating the Shift Manager when plant systems will be taken out and returned to service.

The titles of positions in the Vermont Yankee emergency management Organization are shown in Figure 8.2. Table 8.1 identifies the typically designated alternates for each primary emergency organization position. 'Any qualified individual can be an alternate.

8.2.1. Site Recovery Manager The Site Recovery Manager is a corporate level manager of Vermont Yankee who has the requisite authority, management ability, technical knowledge, and staff to manage the site emergency and recovery organization. The Site Recovery Manager is responsible for the direction of the total emergency response and has the company authority to accomplish this responsibility.

The Site Recovery Manager's principal responsibilities are to:

1. Assume overall responsibility, from either the Plant Emergency Director or the

' " Technical Support Center Coordinator, for the response actions'necessary for.

' control of the'accident and protection of emergency personnel and the public;

2. Assume responsibility from the Plant Emergency Director for offsite States' notification; (non-delegable)

Emergency Plan Revision 39 Page 44 of 166 Entergy Vermont Yankee

3. Assume responsibility, from either the Plant Emergency Director or the Technical Support Center Coordinator, for authorization of escalation, and de-escalation of the emergency;

4. Assume responsibility, from either the Plant Emergency Director or the Technical Support Center Coordinator, for authorization and transmittal of offsite protective action recommendations; (non-delegable)

5. Manage all emergency elements required to restore the plant to a safe condition;

6. Coordinate accident information and assume the role of utility liaison with offsite governmental authorities;

7. Request and direct the use of outside support for recovery operations (e.g.,

equipment, manpower, services);

8. Resolve issues concerning operating license requirements with NRC representatives;

9. Approve public information releases; and

10. Perform or direct the emergency response organization manpower planning effort to assure the availability of sufficient staff to implement all necessary functions, should the emergency response efforts be over a prolonged period.

-The Site Recovery Manager is usually the Senior Operation's Executive of Vermont Yankee.

The Site Recovery Manager or designated alternate is notified of all emergency conditions occurring at the plant. For Alert, Site Area Emergency and General Emergency conditions, the Site Recovery Manager reports to the EOF/RC and directs the activities of the emergency response organizations throughout the emergency condition and until the recovery activities have been terminated.

8.2.2. TSC Coordinator The TSC Coordinator has direct responsibility for the conduct of operations at the plant.

During an emergency situation, the TSC Coordinator is responsible for the overall supervision and coordination of the onsite emergency response activities and directs the activities of the Technical Support Center until the accident is terminated. The TSC Coordinator's primary-responsibilities are to:

1. Assume overall responsibility from the Plant Emergency Director for the response actions necessary for control of the accident and protection of emergency personnel and the public;

2. Assume responsibility from the Plant Emergency Director for authorization of escalation of the emergency; Emergency Plan Revision 39 Page 45 of 166 Entergy Vermont Yankee

3. Assume responsibility from the Plant Emergency Director for de-escalation from an Unusual Event classification only, if conditions warrant;

4. Assume responsibility from the Plant Emergency Director for authorization of off-site protective action recommendations;

5. Assume responsibility from the Plant Emergency Director for notification of off-site NRC authorities;

6. Direct the onsite activities required to restore the plant to a safe condition;

7. Provide technical accident assessment and support to terminate the accident;

8. Analyze instrument and control problems, design and coordinate the installation of short-term modifications, and define emergency operation procedures during the modification period;

9. Analyze problems in the area of system operations, determine emergency procedures related to system operations and establish shift operations support, if applicable;

10. Develop guidance for plant shift operations concerning plant protection of the reactor core;

11. Oversee the accumulation, retention,'retrieval and transmission of vital plant parameters required to analyze the accident progression and subsequent termination;

12. Provide assistance to the Site Recovery Manager on the escalation and de-escalation of the emergency classification as conditions warrant;

13. Initially direct the activities of onsite and offsite teams until EOF becomes operational; and

14. Assign the OSC Coordinator.

Emergency Plan Revision 39 Page 46 of 166 Entergy Vermont Yankee

The General Manager or a designated alternate assumes the role of TSC Coordinator under all emergency conditions. To assist the TSC Coordinator, the TSC is staffed by representatives from the following departments as depicted in Figure 8.3:

Operations

. Maintenance Reactor Engineering Engineering Chemistry

• Radiation Protection

• Security The TSC Coordinator is responsible for directing the overall emergency response organization until the Site Recovery Manager assumes this responsibility.

8.2.3. Plant Emergency Director The Plant Emergency Director is the Duty Shift Manager. The alternate is the Control Room Supervisor of the assigned operating crew in the Control Room at the time of the emergency.

The Plant Emergency Director is responsible for initiating emergency actions to limit the consequences of the event and bring it under control. The immediate responsibilities of the Plant Emergency Director include:

1. Recognition of emergency conditions by observation of characteristic emergency action levels (EALs);

2. Classifications of accident conditions in accordance with the emergency classification system;

3. Implementation of emergency operating procedures applicable to the event condition;

4. Initiation of the appropriate emergency plan implementing procedure;

5. Prompt notification of Vermont, New Hampshire and Massachusetts State Police indicating the event classification; 6; Notification of the NRC indicating the event classification;

7. Initial offsite dose assessment activities; and

8. Offsite protective action 'recommendation and initial transmittal to State officials.

Emergency Plan Revision 39 Page 47 of 166 Entergy Vermont Yankee

Subsequent responsibilities undertaken by the Plant Emergency Director include:

1. Notification of appropriate plant and company management personnel of the emergency conditions;

2. Direction and coordination of all initial emergency response efforts until the support elements of the emergency response organization are activated; and

3. Limiting the consequences of the accident and restoring the plant to a safe condition.

As part of the plant notification system, the Plant Emergency Director has selected plant management and department head personnel notified using a radio paging/telephone system.

This is the mechanism for mobilizing plant support personnel and activating the remainder of the onsite emergency response organization.

8.2.4. EOF Coordinator The EOF Coordinator is a designated staff member of Vermont Yankee management specifically trained to be responsible for the facility Emergency Plan with respect to offsite radiological consequence assessment. The EOF Coordinator, operating from the EOF/RC, will direct offsite radiological activities assessment. The EOF Coordinators primary responsibilities are to:

1. Establish the Emergency Operations Facility when required; 2 2. Assess the onsite and offsite radiological conditions associated with any accidental releases;

3. Continuously update the Site Recovery Manager concerning dose assessment results and their relation to protective action recommendations;

4. Assess Emergency Operations Facility habitability;

5. Document and coordinate emergency team activities; and

6. Prepare the Emergency Operations Facility for the arrival of offsite authorities

-  :-and other support personnel. .

A designated Vermont Yankee management staff member assumes the role of the Emergency Operations Facility Coordinator at an Alert or higher emergency classification. The EOF Coordinator is responsible for reporting to the TSC Coordinator until the Site Recovery Manager assumes full control of the Emergency organization.

Emergency Plan 2 Revision 39 Page 48 of 166 Entergy Vermont Yankee

8.2.5. Operations Support Center Coordinator A member of the plant staff is assigned to coordinate the functions of the Operations Support Center. The TSC Coordinator assigns a qualified individual to this position when required during an emergency situation. The responsibilities of the Operations Support Center Coordinator include:

1. Provide system valve alignment and equipment operation support to the Plant Emergency Director;

2. Assist in coordinating recovery efforts as requested by the TSC Coordinator;

3. Provide Radiation Protection and Chemistry support for the in-plant emergency radiation protection and sampling activities;

4. Assign available personnel to the following emergency team function as necessary:

a. Site Boundary Survey Monitoring Team

b. Offsite Monitoring Teams

c. Onsite Assistance/Rescue Team

5. Assign the OSC Assistant who performs the responsibilities and duties designated by the OSC Coordinator (this will include taking over the command and control of the OSC when the OSC Coordinator has to leave the facility); and

6. Brief OSC teams on in-plant radiation protection controls.

The OSC Coordinator directs the OSC and maintains this facility until the termination of the event. The OSC Coordinator establishes a base of operations in the OSC, but may find it necessary to go to the TSC from time to time.

Emergency Plan Revision 39 Page 49 of 166 Entergy Vermont Yankee

8.2.6. Radiological Assistant During emergency conditions, the Radiological Assistant is responsible for the development of plans and procedures to assess and control radiological exposure in support of and consistent with the emergency response and recovery organization objectives. The Radiological Assistant reports findings directly to the EOF Coordinator. The primary emergency respohsibilities of the Radiological Assistant include:

1. Evaluate offsite doses based on radiation monitoring performed by monitoring personnel;

2. Provide support to the TSC to ensure onsite protective action recommendation (i.e., decontamination procedures, protective clothing, etc.) are being considered and carried out;

3. Recommend offsite radiological protective actions to the EOF Coordinator;

4. Provide radiation protection and control (i.e., respirator fitting, whole body counting, dosimetry control, etc.) for support personnel as needed;

5. Recommend administrative limits for radiological exposure control of emergency workers in keeping with those specified in Table 10.2 and maintain the necessary records; and

6. Review plans and schedules of tasks with appropriate managers and coordinator

.-of the recovery organization concentrating on radiation protection procedures...

The Supv., Rad Control or a designated alternate fills this position.

8.2.7. Radiological Coordinator The Radiological Coordinator assumes responsibility for directing the Chemistry and Radiation Protection staffs in providing analytical services needed for the interpretation of the offsite radiological impact of the accident. The Radiological Coordinator reports staff findings directly to the Radiological Assistant. The emergency responsibilities of the Radiological Coordinator include:

1. Establish the coordination of radiological analysis of offsite samples;

2. Receive and document all sample results;

3. Transmit sample results data to the Radiological Assistant; and

4. Coordinate the assessment activities and resolve any discrepancies with offsite response and assistance organizations.

Emergency Plan 9~ Revision 39 Page 50 of 166 Entergy Vermont Yankee

The immediate priority of the Radiological Coordinator and staff is radiological analysis of air samples taken by offsite monitoring teams. For the long-term, additional duties include the analysis of contamination levels in area vegetables, fruits, milk, or water, and soil samples. To accomplish this long-term requirement, the Radiological Coordinator works closely with the services provided by support organizations (e.g., Environmental Lab).

This position is filled by the'ALARA Engineer or designated alternate.

8.2.8. Purchasing Coordinator The Purchasing Coordinator is authorized to provide administrative, logistic and communication services for the emergency organization at the site. Specifically, the responsibilities of the Purchasing Coordinator include:

1. Function as an aid to the Site Recovery Manager;

2. Acquire the resources required by all site emergency management disciplines;

3. Assist in arranging for near-site accommodations (i.e., housing, transportation, etc.) of incoming emergency response personnel;

4. Assist in arranging for food and potable water for personnel at all emergency response centers;

5. Maintain 'adequate contractual communication services for the site emergency.

• -' organization; and '

6. Initially be responsible for procurement using established emergency procurement procedures.

NOTE: Subsequently, normal Purchasing Department operations and procedures are used as directed by the Site Recovery Manager.

The Purchasing Coordinator establishes operations at the EOF/RC and assists the Site Recovery Manager, as requested. The Manager, Materials, Purchasing and Contracts or a designated alternate fills the position of Purchasing Coordinator.

Emergency Plan Revision 39 Page 51 of 166 Entergy Vermont Yankee

8.2.9. Security Coordinator The Manager, Security Operations or a designated alternate directs the security personnel in maintaining required security in support of the emergency operations. The functional responsibilities of the Security Coordinator include:

1. Establish security around the plant site and/or any other areas identified by the Plant Emergency Director;

2. Call for required offsite police support, if necessary;

3. Manage site evacuation;

4. Provide initial accountability of personnel in the protected area; and

5. Maintain overall plant security in accordance with the Plant Security Plan.

The Security Coordinator interfaces with the TSC Coordinator for in-plant security actions.

8.2.10. Nuclear Information Director The Nuclear Information Director is authorized to provide the public with information concerning the emergency. The emergency responsibilities of the Nuclear Information Director include:

1. Establish a Joint News Center when necessary;

2. Coordinate information at the Joint News Center with counterparts from local, state and federal agencies and with other companies involved with the emergency; and

3. Present terminology concerning accident conditions in an easily understood and informative manner to the press.

During an emergency, the Nuclear Information Director reports to the Site Recovery Manager.

The Director of Public Affairs or a designated alternate fills the position of the Nuclear Information Director.

8.2.11.. Decision Maker During implementation of Severe Accident Management (SAM), the senior licensed individual in the TSC will assume the role of Decision Maker as defined in the SAM Guideline (PP 7019).

Emergency Plan.

Revision 39 Page 52 of 166 Entergy Vermont Yankee

8.2.1 2. Engineering Support Group The Engineering Support Group is an engineering group established to provide emergency support for plant assessment and recovery operations. This group is activated for an Alert, Site Area and General Emergency. The support group includes personnel from the various onsite engineering groups. In addition, the engineering support group may access offsite engineering resources through the support programs listed in Appendix G. This group

-maintains communications with the Technical Support Center, EOF/RC and offsite technical support personnel. This group has access to the technical expertise to provide a variety of emergency functions, such as engineering analyses, radiological evaluation, and plant system assessment in support of recovery efforts.

8.3. Recovery Organization The emergency measures presented in this plan are actions designated to mitigate the consequences of the accident in a manner that afford the maximum protection to the public.

Planning for the recovery mode of operations involves the development of general principles and an organizational capability that can be adapted to any emergency situation. The emergency response organization described in Section 8.1 and 8.2 provides the foundation for such a recovery organization.

The Site Recovery Manager directs the recovery organization. As indicated in Figures 8.1 through 8.5, the organization relies on more than plant staff and/or resources to restore the plant to normal conditions. The expertise provided through the support plans is available to aid with the necessary corrective actions required to control and/or restore normal plant status.

Various State and Federal support groups augment the recovery organization. The following is a brief summary of the recovery organization's responsibilities:

1. Maintain comprehensive radiological surveillance of the plant to assure continuous control and recognition of problems;

2. Control access to the area and exposures to workers;

3. Decontaminate affected areas and/or equipment;

4. Conduct clean-up and restoration activities;

5. Isolate and repair damaged systems;

6. Document all proceedings of the accident and review the effectiveness of the emergency organization in reducing public hazard and/or plant damage;

7. Provide offsite authorities with status report as to the operations capabilities of the plant; Emergency Plan Revision 39 Page 53 of 166 Entergy Vermont Yankee

8. Provide assistance to recovery actions undertaken by state/local authorities, if requested; and

9. Provide the public with information on the status of the recovery efforts (i.e., via press, TV/radio, etc.).

When plant conditions allow a transition from the emergency phase to the recovery phase, the Site Recovery Manager conducts a plant emergency management meeting to discuss the recovery organization. The actions taken by this organization concerning termination of the emergency proceeds in accordance with a recovery plan developed specifically for the accident conditions.

8.4. Extensions of Vermont Yankee Emergency Organization 8.4.1. Local Service Arrangements have been made for the extension of the emergency organization capability for handling emergencies to provide for:

1. Transportation of injured personnel using an ambulance service;

2. Treatment of radioactively contaminated and injured personnel at a local support hospital (Brattleboro Memorial and Franklin Medical Center) and other regional medical facilities as specified in the local support hospital plans; and

3. Fire support services by the Vernon and Brattleboro Fire Departments and the Tri-State and Southwestern Fire Mutual Aid Networks.

4. Law enforcement support services provided by local, county, state, and federal law enforcement authorities as appropriate and response capabilities are documented in the letters of agreement maintained by Security.

Evidence of agreements with participating local services is found in Appendix E, Vermont Yankee Fire Protection, Appendix R Program, PP 7011, and the Annual Law Enforcement Letters of Agreement (Safeguards Information) maintained by Security.

8.4.2. Federal Government Support

' Resourc'es of federal agencies appropriate to an emergency condition are made available in accordance'with the Federal Radiological Emergency Response Plan. This plan and'the' resources behind it are activated through the plant notification of the NRC. Many resources are made available, as deemed necessary by the emergency condition, including a major effort under the leadership of the Department of Energy applied to the area of offsite radiological impact assessment. This effort can involve manpower and equipment for extensive plume measurement, including aerial monitoring and tracking, and sampling and analysis of ingestion pathway media.

Emergency Plan Revision 39 Page 54 of 166 Entergy Vermont Yankee

8.4.3. Additional Support Dependent upon the emergency condition and response needs, the Vermont Yankee emergency organization can be augmented by manpower and equipment support from the remainder of the Entergy Nuclear organization. This support capability is outlined in the Corporate Support procedure as referenced in Appendix G.

Should response support beyond this level be required, additional support from other nuclear industry organizations can be requested through interface with the Institute of Nuclear Power Operations (INPO). Informational notifications are provided to this organization whenever emergency conditions escalate to an Alert pr greater emergency condition. The decision to request additional industry support is a responsibility of the Site Recovery Manager. All industry support organizations reporting to the site are assigned by emergency management, located in the EOF/RC, who specify their authorities, responsibilities and any limits on their actions. All responding parties are required to adhere to existing plant procedures while completing their assignments.

8.5. Coordination With State Government Authorities Because of the location of the Vermont Yankee Plant, the planning and/or action responsibilities at the state level involves coordination of three states; Vermont, New Hampshire, and Massachusetts. Section 7.0 describes the extensive communications network between Vermont Yankee and these states as a means of promptly notifying appropriate authorities under accident conditions. Table 8.3 provides a summary of emergency plan areas and the associated plant, state and local responsibilities.

The Plant Emergency Director initiates the coordination effort by notifying Vermont, New Hampshire and Massachusetts State Police, providing them with an established message format which described the accident status. Based on the emergency class, the State emergency response personnel are alerted and/or mobilized. To ensure effective coordination of offsite emergency response actions, representatives of each state are assigned to report to the EOF/RC for first-hand emergency information and assessment. They are provided space in the EOF/RC as shown in Figure 6.4. The Site Recovery Manager or designee issues periodic accident reports to the responding State Representative. Each state representative is responsible for transferring the content of these status reports to their respective State Emergency Operating Center (EOC). If additional technical expertise is required by state authorities at the state Emergency Operating Centers (EOCs), the Site Recovery Manager can authorize dispatching of technical support staff to assist them in comprehension of any emergency communications.  :

Emergency Plan Revision 39 Page 55 of 166 Entergy Vermont Yankee

Based upon the accident assessment, protective measures are recommended and implemented by each state according to actions and decisions prescribed by each state's Emergency Plan. The Vermont Health Department will notify the New York State Department of Public Health concerning all ingestion pathway considerations. Additional state support can be called upon from any or all other New England states through the agreement specified in the New England Compact on Radiological Health Protection.

Emergency Plan Revision 39 Page 56 of 166 Entergy Vermont Yankee

TABLE 8.1 (Page I of 2)

EMERGENCY ORGANIZATION STAFFING ASSIGNMENTS DESIGNATED PERSONNEL ASSIGNED POSITION ' PRIMARY - ALTERNATE(S)

Titles are typical alternates, any qualified individual may fill the position.

Site Recovery Manager Site Vice President Manager, Training & Development Manager, System Engineering Manager, Engineering Support Director of Nuclear Safety Manager, Tech Support TSC Coordinator General Manager Manager, Operations Manager, Technical Support Assigned Duty on Call Officer EOF Coordinator Designated Managerr ient Designated Management Staff Staff Plant Emergency Director Shift Managers Control Room Supervisors OSC 'Coordinator Assistant Operations Supt., Work Management Manager Designated Management Staff Radiological Assistant Supv., Rad Control Dosimetry/HP Specialist Supervisor, HP Designated Management Staff Radiological Coordinator ALARA Engineer Supervisor, HP Dosimetry/HP Specialist Purchasing Coordinator Manager, Materials, Supv., Contracts Purchasing and Contr acts Contract Admin.

Nuclear Information Director of Public Affairs Company Spokesperson Director Corp. & Comm. Relations Rep.

Security Coordinator. Manager, Security Security Operations Specialist Operations Designated.Security Staff' Engineering Coordinator Director, Engineering Manager, System Engineering Manager, Design Engineering Manager, Engineering Support Designated Management Staff Reactor Engineering Supt., Reactor Engineering Reactor Engineer Coordinator Designated Management Staff Emergency Plan Revision 39 Page 57 of 166 Entergy Vermont Yankee

TABLE 8.1 (Continued)

(Page 2 of 2)

EMERGENCY ORGANIZATION STAFFING ASSIGNMENTS DESIGNATED PERSONNEL ASSIGNED POSITION PRIMARY ALTERNATE(S)

Operations Coordinator Mgr., Operations Shift Managers Assistant Ops Manager Designated Management Staff Maintenance Coordinator Supt., Electrical & Supv., Mechanical Mechanical Supv., Electrical Supt., I&C Supv., I&C Designated Staff Radiation Protection Supt., Radiation Protection Supv., HP Coordinator Designated Staff Chemistry Coordinator Supt., Chemistry Supv., Chemistry Designated Staff Decision Maker Senior Licensed Individual Emergency Plan Revision 39 Page 58 of 166 Entergy Vermont Yankee

c C -

C TABLE 8.3 (Page 1 of 3)

A SUMARY OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION PLANT RESPONSIBILITY STATE RESPONSIBILITY LOCAL RESPONSIBILITY Protective Action Decision Making The Plant Emergency Director or TSC State Police receive the initial The State Directors of Emergency Coordinator issues the Initial protective

• notification whereupon they activate Management Agencies will notify action recommendation. the State fan-out notification process. either the local emergency management directors or the selectmen of the recommended action and advise.

After the Site Recovery Manager In the State of Vermont, the Director of (SRM) assumes overall responsibility, the Vermont Emergency Management the SRM will Issue protective action Agency and the Director of the recommendations to the appropriate Division of Occupational Health and State authorities (non-delegable). Radiological Health and Safety would activate.

In the Commonwealth of Massachusetts, the Director of the Massachusetts Emergency Management Agency and the Director of the Radiation Control Branch of the Massachusetts Department of Public health would activate.

In the State of New Hampshire, the Director of the New Hampshire Office of Emergency Management and the Division of Public Health Services would activate.

Each State Health representative would call or report to the plant for the follow-up protective action recommendation issued by the Site Recovery Manager.

Emergency Plan Revision 39 Page 59 of 166 Entergy Vermont Yankee

c C TABLE 8.3 (Continued)

(Page 2 of 3)

A SUMARY OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION PLANT RESPONSIBILITY STATE RESPONSIBILITY LOCAL RESPONSIBILITY Protective Action Decision Making Each State Health representative will (continued) review all factors and issue a final recommendation to the Directors of State Emergency management Agencies, who, in turn, will initiate response actions to implement this recommendation.

.A coordination between the States will decide the time to implement the proposed actions, including activating the public alert and instructional methods (e.g., siren activation/NOA

message, etc.)

Coordination of Radiological Data : The Radiological Coordinator is Each State Health representative at Local communities rely on State responsible for compiling offsite the EOF/RC will request monitoring capability for radiological evaluation.

monitoring results and for ensuring an updates from the EOF Coordinator.

effective deployment of monitoring personnel.

The EOF Coordinator is responsible In the State of Vermont, the Director of for coordinating information transfer. the Division of Occupational &

Radiological Health & Safety will command this function at the State EOC.

The Site Recovery Manager will In the Commonwealth of advise the State response personnel Massachusetts, the Director of the of results. Radiation Control Branch of the Massachusetts Department of Public Health will command this function at the State EOC.

Emergency Plan Revision 39 Page 60 of 166 Entergy Vermont Yankee

C c TABLE 8.3 (Continued)

(Page 3 of 3)

A SUMARY OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION PLANT RESPONSIBILITY STATE RESPONSIBILITY LOCAL RESPONSIBILITY Coordination of Radiological Data In the State of New Hampshire, the (continued) Director of the Division of Public Health Services will command this function at the State EOC.

Plant Access Control The Security Coordinator State Police would respond as Local police would assist as coordinates plant site security and directed by the Directors of the directed by the State Police.

offsite law enforcement support as Emergency Management necessary. Agencies.

Evacuation Process Plant Emergency Director will State Emergency management sound evacuation alarm under Site Agencies will coordinate the Area or General Emergencies. *activation of the Public Notification System.

OSC Coordinator will direct Health and Human Services or personnel to monitor all plant Red Cross representative will evacuees. coordinate the establishment of Reception Centers.

Public Information Release The Site Recovery Manager issues State press personnel report to the Media inquiries are referred to the final approval prior to release. Joint News Center. Joint News Center.

The Media Advisor at the EOF/RC State press personnel coordinate relays accident status reports to releases with the Nuclear the Joint News Center. Information Director.

The Nuclear Information Director releases the information to the media.

Emergency Plan Revision 39 Page 61 of 166 Entergy Vermont Yankee

Table 8.4 (Page 1 of 2)

MINIMUM STAFFING REQUIREMENTS FOR THE ENVY ERO FUNCTIONAL MAJOR TASKS ENVY POSITION TITLE' RESPONSE AREA TIME Plant Operations & Shift Manager (1) On Shift Assessment of SCRO (1) On Shift Operational Aspects CRO (2) On Shift AO (3) On Shift Emergency Direction Shift Manager (1*) On Shift

& Control (Emergency Coordinator)**

Notification / Notify Licensee, State STAI Shift Chem. Tech On Shift Communication*** local and federal TSC OPS Coord. / EOF OPS Advisor (1) 3 30 min.

personnel & maintain TSC OPS Coord.I EOF OPS Advisor (2)3 60 mi.

communication Radiological Emergency Operations EOF SRM (1) 60 min.

Accident Facility (EOF) Director Shift Mgr/SCRO/STA On Shift Assessment and Offsite Dose assessment EOF Rad Asst/TSC RP Coord/ EOF Rad 30 min.

Support of Coord (1)4 Operational Accident Off site surveys Field monitoring teams (2) 30 min.

Assessment Field monitoring teams (2) 60 min.

Onsite (out of plant) Shift RP tech (1) On Shift Field monitoring teams (1)3 30 min.

Field monitoring teams (1) 60 min.

Inplant surveys Shift RP Tech (1) On Shift RP staff (1) 30 min'.

RP staff (1) 60 min.

Chemistry I Shift Chem. Tech (1) On Shift Radiochemistry Chem staff (1) 60 min.

Plant System Shift Technical Advisor STA (1) On Shift Engineering Core/Thermal hydraulics TSC RE Coord (1) 30 min.

Electrical TSC Eng Coord / TSC&EOF Engineering 60 min.

Support staff (1)

Mechanical TSC Eng Coord / TSC &EOF Engineering 60 min.

Support staff (1)

Repair & Corrective Mechanical Maintenance Shift AO (1**) On Shift I Actions Mechanical Maintenance Maintenance (1) 60 min.

Rad Waste operator AOIACRO/CR0 (1) 60 min.

Electrical Maintenance / Shift AO (1**) - - On Shift Instrumentation & Control Maintenance (1) 30 min.

. Technician - Maintenance (1) - 60 mi.

Instrumentation & Control Maintenance (1) 30 min.

Technician Emergency Plan Revision 39 Page 62 of 166 Entergy Vermont Yankee

Table 8.4 (Continued)

(Page 2 of 2)

MINIMUM STAFFING REQUIREMENTS FOR THE ENVY ERO FUNCTIONAL MAJOR TASKS ENVY POSITION TITLE' RESPONSE AREA TIME Protective Actions Radiation protection, Shift AO (2**) On Shift (In Plant) access control, HP RP, (2) 30 min coverage for repair, RP (2) 60 min corrective actions, search

& rescue, first aid &

firefighting, personnel monitoring, dosimetrv Fire Fighting Fire brigade. SE is FBL, 3 AO, and 1 On Shift Security (5**)

Local support 30 min.

Local support 60 min.

Rescue Operations Security (2**) On Shift

& First Aid Local support 30 min.

Local support 60 min.

Site Access Control Security, firefighting, Security Force On Shift

& Personnel communications, Accountability personnel accountability NOTE: Response times are from NOTIFICATION of the event and are based on optimum travel conditions.

• • May be provided by shift personnel assigned other functions Overall direction of facility response to be assumed by EOF director when all centers are fully manned. Direction of minute to minute facility operations remains with senior manager in technical support center or control room.

May be performed by engineering aide to shift supervisor (STA for ENVY)

NOTES I. AP 0894 specifies minimum shift staffing requirements. FB requires 5 persons per Tech Spec. STA and Chemistry Tech must be available within 10 minutes to the Control Room. VY letter to NRC dated 4/18/1981 establishing position. VY letter to NRC 6/22/1982 Supplement -NUREG 0737 Item IIIA.1.2 on training of on-shift staff to support VY position for staffing. VY letter to NRC 4/18/1981 TMI Action Plan Item III.A.1.2, goal for augmentation of staff. VY letter to NRC 6/15/82 Results of Augmentation drills to support use of goals.

Titles of ENVY ERO positions are shown.

2. All AOs use digital dosimeters with features for dose rate and total dose monitoring plus AOs are capable of doing own HP work. .

3. ENVY has designated pager holders who staff positions required to meet minimum staffing to activate TSC, OSC and EOF (see E Plan Figures 8.3 through 8.5). There are a minimum of 4 persons per position (4 teams who rotate duty). However, all persons on teams are expected to respond. In addition, all other ERO personnel not on pagers are notified by the emergency call-in notification system and are expected to respond.

4. The on-shift Shift Manager, SCRO and STA have the capability to do initial dose assessment and PAR. The TSC and EOF radiation assessment staff relieves them of this function.

Emergency Plan Revision 39 Page 63 of 166 Entergy Vermont Yankee

( C: C r - - - - -Y

__ Security

• T - ----- I  :

3ER -

[_] Duty On Call Shift ____ . Officer Technical .,' l Advisor Chemistry: l t1]lRadiation Protection

• Technician Technician

.[1]

Control Room Operators

. .I ll [2] Note

.... .._ Corrective action repair is performed by Operations Staff on-shift until supplemented by additional ERO Auxiliary Staff.

[xj = Number of Individuals Operators

[3]

Figure 8.1 Normal On-shift Emergency Organization Emergency Plan

• Revision 39 Page 64 of 166 Entergy Vermont Yankee

SITE RECOVERY MANAGER Engineering

- . ISupport S Organizatiorn:

Purchasing L - - - _-_ _ J Coordinator lear NEucF Tnical Support Center E.O.Information Coordina t or Director Coordinator Radiological..

Assistant Oeain

.Sc tOpera tions Plant SlCrinto Support Center Emergency Radiological jCodntrCoordinator Director Coordinator  :

Figure 8.2 VY Emergency Management Organization Emergency Plan Revision 39 Page 65 of 166 Entergy Vermont Yankee

c C C Operations Chemistry Coordinator* Coordinator*

Severe Accident Radii tionn Management .or Poeto Coordinator Decision Maker Minimum Staffing forActivation of the TSC Includes:

or-- --__, . TSC Coordinator X Additional X

• Any Engineering Discipline Representative (Design, System.

I Engineering' Project) may become Coordinator Support

.

• Any Maintenance Discipline Representative (ElectJMech..

I&C. Support) may become Coordinator

• Security Representative

• Operations Representative

• Reactor Engineering Representative Radiation Protection Representative

' required for activation Chemistry Representative

- .Figure 8.3 Technical Support Center Emergency Organization Emergency Plan Revision 39 Page 66 of 166 Entergy Vermont Yankee

Coordinator *

., .- ' SC '.

Coordinator's Assistant Work Electrical Mechanical Radlation Managment Maintenance Maintenance Protection Chemistry M Man Operatrotetio Staff Staff Staat NOTES: 1. OtheramartencydIscipflnesareassigned in eccofrdance wfth the prlonrlos of tho omoirencyq r r 7he Onl~ff Ste Teems am staffed with personnel required for acthvatlon. reporflng to the OSC.

Figure 8.4 Operations Support Center Emergency Organization Emergency Plan Revision 39 Page 67 of 166 Entergy Vermont Yankee

C C C

• SITE RECOVERY MANAGER

• 1I

.. I *SRMStaff

. I - c A i . i I

EOF Coorcdinator *

.... I-I Cmlace Advisor

• _~ If Ops Advisor I

logical Assistant

• Manpower & Planning Assistant SeurtySupport I

I I

. ,:. Ir State Emergency Response I

Mass. State Liaison Vermont State Liaison New Hampshire State Liaison

] Federal Emergency Response NRC Liaison FEMA Liaison

• required for activation '

Figure 8.5 Emergency Operations Facility Organization Emergency Plan Revision 39 Page 68 of 166 Entergy Vermont Yankee

ea .NRC/FEMA/State 1 Infor t-- O P10S Director 0 NID Press Release Technical Floor Assistant Writer Representatives (2) Liaisons (2) l

• JointNewsFacilities Center Coordinator Coordinator NRC/FEMAiStafe Security Assistants (Contractor)

Public Inquiry mergency Info Coordinator Coordinator Media Public Inquiry Distribution Status Status Board Monitoring Responders Staff Phone Recorder Coordinator& Asst

• required for activation Figure 8.7 Joint News Center Organization Emergency Plan Revision 39 Page 69 of 166 Entergy Vermont Yankee

9.0 EMERGENCY RESPONSE 9.1. Emergency Condition Recognition and Classification Section 5.0 presents the emergency classification system used for categorizing the wide spectrum of possible emergency conditions into one of four emergency classes. The process of condition recognition, immediate response to correct the condition, event classification, and initiation of the appropriate emergency implementing procedures are all critical responsibilities of the Shift Manager/Plant Emergency Director and his operations crew. This has been recognized in the design of both the emergency operating and emergency implementing procedures. The step between condition recognition and classification is handled as a procedural transition from the emergency operating procedure applicable to the event, to a specific emergency implementing procedure.

The specific transition procedure contains the listing of conditions that represents each of the four emergency categories and the detailed Emergency Action Levels (EALs) that allow the Shift Manager/Plant Emergency Director to determine the emergency classification. Once the emergency is classified, the applicable emergency implementing procedure is initiated. This is the trigger for the activation of the plant emergency response organization and the notification of offsite authorities for the activation of their emergency response. The activation of the plant emergency response organization brings to the assistance of the operations shift personnel all the various support elements described in this plan. How specific support elements are implemented, are detailed in the emergency implementing procedures. See Appendix G for a listing of these procedures.

9.2. Activation of the Emer ency Organization The Shift Manager/Plant Emergency Director activates the emergency organization if plant conditions reach predetermined Emergency Action Levels (Appendix A). Depending upon the specific action levels attained, the Shift Manager declares one of the following: Unusual Event, Alert, Site Area Emergency, or General Emergency.

9.2.1. Unusual Event Response Appendix A defines the conditions that require the declaration of an Unusual Event.

Emergencies defined within this classification demand the mobilization of specific emergency response members and the initiation of precautionary and/or corrective actions which mitigate the'consequences of the event. An Unusual Event does not activate the entire emergency response organization, but may require augmentation of on-shift resources to deal with the event. Offsite emergency organizations are notified for informational purposes, and aid from offsite fire, medical, and security organizations may be required depending on the nature of the event.

Emergency Plan Revision 39 Page 70 of 166 Entergy Vermont Yankee

The response required as a result of this declaration of an Unusual Event varies according to the specified event, but a general summary of actions taken is described below:

1. The emergency condition is recognized and classified by the Shift Manager/Plant Emergency Director who instructs Control Room personnel to announce over the plant page system the emergency classification;

2. The on-duty operations shift and selected'plant personnel respond as directed by the Shift Manager;

3. The Shift Technical Advisor reports to the Control Room and provides technical support as necessary;

4. Appropriate plant staff are directed to assume various emergency functions;

5. Control Room personnel notify the New Hampshire, Massachusetts and Vermont State Police. The State Police notify the appropriate state authorities;

6. The NRC is notified;

7. Other support is requested as necessary;

8. The Emergency Call-in Method is implemented as shown in the notification plan (Figure 9.1);

9. The Duty on Call Officer (DCO) reports to the plant and assumes the role of the' TSC Coordinator;

10. The Shift Manager/Plant Emergency Director directs the activities of emergency response personnel until overall responsibility is assumed by the TSC Coordinator;

11. Ifnecessary, appropriate emergency medical, fire department, or law enforcement agencies are notified and requested to respond;

12. The TSC may be activated at the discretion of the TSC Coordinator;

13. The public information representative is notified and handles public information associated with'the event; and' .

14. The TSC Coordinator or designee terminates the Unusual Event status and closes out the event with a verbal summary to offsite authorities or escalates to higher level emergency classification.

Emergency Plan Revision 39 Page 71 of 166 Entergy Vermont Yankee

9.2.1 .1. Unusual Event (Terminated) Response If a condition that warrants an Unusual Event declaration has occurred, and was immediately rectified such that the condition no longer existed by the time of declaration, this Unusual Event classification is referred to as an Unusual Event (Terminated).

The event or condition did not affect personnel onsite or the public offsite, or result in radioactive releases requiring offsite monitoring.

The response to this declaration of an Unusual Event (Terminated) is not as comprehensive as that for an Unusual Event. All the same notifications for an Unusual Event are made, and, except for the DCO, emergency response personnel reporting to the plant are based on specific requests of the SM/PED.

9.2.2. Alert Response An Alert requires actions to: 1) assure that sufficient emergency response personnel are mobilized to respond to the accident conditions at the site; and 2) that offsite emergency organizations are readily available to respond to the situation. Prompt notification is made to state officials and follow-up information is provided as needed to offsite emergency organizations. Unassigned personnel are evacuated from the site. In an Alert, the steps listed in the Unusual Event Response section (except for the termination process) and the following are performed:

1. The Alert emergency notification and response, as shown in Figure 9.1 and' described in Table 9.1 are implemented;

2. The Technical Support Center, Operations Support Center, the Emergency Operations Facility/Recovery Center, and the Joint News Center (optional) are activated by personnel as shown in Table 9.1;

3. If sufficient personnel are not available onsite, off-duty personnel are called in as specified in the emergency implementing procedures;

4. The TSC Coordinator reports to the Technical Support Center and directs in-plant emergency operations;

5. The EOF Coordinator establishes operations in the EOF/RC;

6. The Vermont, Massachusetts, and New Hampshire state emergency response personnel, having been notified through the state fan-out process, respond in accordance with their respective Radiological Emergency Response Plans;

7. The Site Recovery Manager reports to the EOF/RC and assumes total responsibility for overall emergency response actions and recovery; Emergency Plan Revision 39 Page 72 of 166 Entergy Vermont Yankee

8. Offsite authorities are provided periodic meteorological assessments and, if releases are occurring, projected dose estimates. (Note: If radiological releases are occurring, monitoring teams are dispatched.); and

9. The Site Recovery Manager reaches agreement with offsite authorities concerning de-escalation or termination of the event, and closes out the event by verbal summary to offsite authorities. If an event is a reportable occurrence, a written summary is issued to these authorities in an appropriate time frame through distribution by the Emergency Plan Manager.

9.2.3. Site Area Emergency Response Activation of all emergency response facilities takes place upon declaration of a Site Area Emergency. In a Site Area Emergency, the steps listed in the Alert Response section and the following are performed:

1. All Vermont Yankee emergency response personnel are notified and report as described in Table 9.1;

2. As Vermont Yankee staff report to the EOF/RC, the EOF Coordinator assigns duties in accordance with the priorities of the emergency;

3. The Joint News Center is established and timely public information is presented through coordination between the Site Recovery Manager and offsite authorities;

4. The Engineering Support Group works in concert with the TSC to resolve engineering support, analyze offsite dose conditions, and assist in coordinating manpower and equipment resources;

5. State emergency response personnel are dispatched to the EOFIRC as state/local emergency response organizations become fully mobilized;

6. Plant conditions are continually assessed and protective action recommendations to offsite authorities are made on the basis of this assessment and/or actual or projected offsite radiological impacts;

7. Termination actions are initiated in the same manner as that identified for an Alert. A closeout, de-escalation to recovery phase, or escalation of the emergency classification is made in coordination with offsite authorities.

Emergency Plan Revision 39 Page 73 of 166 Entergy Vermont Yankee

9.2.4. General Emergency Response All Emergency Centers are activated and all available resources are called upon in the event of a General Emergency. The plant promptly notifies offsite authorities and initiates all emergency response organization capabilities.

Offsite authorities fully activate their emergency response and implement appropriate protective measures based on meteorological information, actual or projected radiological dose conditions and/or conditions. The Site Recovery Manager and the entire emergency response organization assemble plant status parameters and continually advise offsite authorities of the type of public protective action most appropriate to the situation based on plant conditions and offsite dose projections. This includes whether to shelter or evacuate the affected towns within the plume exposure emergency planning zone. In a General Emergency, the steps listed in the Site Area Emergency Response section and the following are performed:

1. The Site Recovery Manager may request that the Engineering Support Group mobilize other personnel in support of Vermont Yankee through activation of the Corporate Support Center;

2. Other nuclear industry resources are alerted and requested to render appropriate assistance;

3. The full resources of the Federal Radiological Emergency Response Plan are activated; and

'4. Dissemination of information and instructions associated with protective actions to the public is the principal focus of all response organizations. The plant fully participates in these efforts by providing detailed emergency condition information.

9.3. Emercency De-Escalation and Termination Criteria Classification of an accident condition requires that the plant operation staff recognize that pre-established EALs associated with an emergency condition, as defined in Appendix A, have been reached or exceeded.

De-escalation criteria require (1) an extensive review of plant parameters and/or offsite radiological conditions in conjunction with the pre-established EALs; (2) review of plant and offsite conditions with offsite authorities; and (3) concurrence by offsite'authorities as to the appropriate time frame required to implement de-escalation.

Emergency Plan Revision 39 Page 74 of 166 Entergy Vermont Yankee

De-escalation from an Unusual Event to a recovery phase requires satisfying the following criteria:

1. Criticality controls are in effect;

2. The core is being adequately cooled;

3. The fission product release has been controlled;

4. Control has been established over containment pressure and temperature;

5. An adequate heat transfer path to an ultimate heat sink has been established;

6. Reactor coolant system pressure is under control; and/or

7. Unusual Event Conditions (from AP 3125) have been reviewed, are under control, and are not expected to deteriorate further.

De-escalation from emergency classes greater than the Unusual Event level to a recovery.

phase requires satisfying all the criteria stated in Items 1 through 6 above and that the States of Vermont and New Hampshire, and the Commonwealth of Massachusetts reach agreement with the Site Recovery Manager or designee that there is no longer a need for either consideration of further public protective action or surveillance related to public protective action. ..

When plant conditions allow de-escalation in the emergency class to a recovery phase, the Site Recovery Manager or the TSC Coordinator directs the emergency response organization to perform certain response actions prior to implementing any change. These actions include:

1. Notification of all plant emergency management personnel of the pending change;

2. Notification of offsite authorities of the pending change;

3. Notification of corporate support services of the pending change;

4. Coordination of media releases concerning the transition; and

.5. Announcement of the.transition over the plant page system.

Emergency Plan Revision 39 Page 75 of 166 Entergy Vermont Yankee

C c TABLE 9.1 (Page1. of 2)

VERMONT YANKEE EMERGENCY RESPONSE EMERGENCY CENTER .UNUSUAL EVENT ALERT SITE AREA OR GENERAL EMERGENCY Technical Support Center Activation at the discretion of the TSC Coordinator TSC Coordinator TSC Coordinator Maintenance Coordinator Maintenance Coordinator (Electrical/Mechanical/ &C) (ElectricallMechanical/lI&C)

Radiation Protection Coordinator Radiation Protection Coordinator Reactor Engineering Coordinator Reactor Engineering Coordinator Engineering Coordinator (Project, System, Engineering Coordinator (Project, System, Design), Design)

Chemistry Coordinator Chemistry Coordinator Decision Maker Decision Maker Operations Support Center Not activated OSC Coordinator OSC Coordinator Radiation Protection Staff Radiation Protection Staff Chemistry Staff Chemistry Staff Spare Licensed Operators Spare Licensed Operators Spare Auxiliary Operators Spare Auxiliary Operators Control Instrument Specialists Control Instrument Specialists Plant Mechanics Plant Mechanics.

Emergency Plan Revision 39 Page 76 of 166 Entergy Vermont Yankee

( C c TABLE 9.1 (Continued)

(Page 2 of 2)

VERMONT YANKEE EMERGENCY RESPONSE EMERGENCY CENTER UNUSUAL EVENT ALERT SITE AREA OR GENERAL EMERGENCY Emergency Operations Activation at the discretion of the Site Recovery Manager Site Recovery Manager Facility/Recovery Center TSC Coordinator EOF Coordinator EOF Coordinator Purchasing Coordinator Purchasing Coordinator Plus other plant personnel called by EOF Plus other plant personnel called by EOF Coordinator according to needs and ERO Coordinator according to needs and ERO Assignments: Assignments:

EOF Coordinator's Asst. EOF Coordinator's Asst.

Radiological Asst. Radiological Asst.

Manpower & Planning Asst. Manpower & Planning Asst.

Communications Asst. Communications Asst.

Radiological Coordinator Radiological Coordinator Personnel & Equipment Monitoring Personnel & Equipment Monitoring

• Site/Offsite Monitoring Teams *Site/Offsite Monitoring Teams Media Advisor Media Advisor Environmental Lab Personnel Nuclear Industry Assistance Joint News Center Not Activated Not activated unless necessary to Nuclear Information Director accommodate public interest VY Public Information Staff Nuclear Public Information Representatives Joint News Center Staff

• Deployed from OSC and report to EOF Coordinator Emergency Plan Revision 39 Page 77 of 166 Entergy Vermont Yankee

c c c STATE NOTIFY STATE AUTHORITIES AND IMPLEMENT STATE RADIOLOGICAL POLICE 3 STATES EMERGENCY RESPONSE PLAN CLASSIFY SHIFT INCIDENT ENS l F Z IMPLEMENTS FEDERAL RADIOLOGICAL EMERGENCY RESPONSE PLAN MANAGER AND NOTIFY GAI.

TRONICS PLANT PER EMERGENCY PLANT RESPOND AS ASSIGNED SECURITY RESPONSE CALL-IN PROCEDURE PERSONNEL Figure 9.1 Notification Plan Emergency Plan Revision 39 Page 78 of 166 Entergy Vermont Yankee

10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES

_J 10.1. Radiological Assessment 10.1.1. Initial Offsite Radiological Dose Projection Capability Vermont Yankee has developed two methods to quickly determine the projected offsite radiological conditions at various distances downwind of the plant site. During the initial stages of an emergency, the Shift Manager/Plant Emergency Director or designated individual is responsible to perform the initial evaluation of offsite radiological conditions. The initial evaluation of offsite radiological conditions is accomplished by utilizing the Offsite Dose Projection System (ODPS) or the Offsite Dose Nomogram.

The ODPS utilizes a straight line Gaussian plume dispersion model programmed on the plant process computer. The program allows the user the option to select one of two release pathways (elevated or ground) and to utilize site-specific radiological and meteorological information to estimate the Total Effective Dose Equivalent and adult thyroid Committed Dose Equivalent (Elevated release only) at a distance of 0.35 miles to 10 miles from the plant site.

The Offsite Dose Nomogram can be used to determine an activity release rate (1 iCi/sec) and a projected offsite whole body plume centerline dose rate (mR/hr) at 1/3 of a mile from the stack.

These determinations are made by using Figure 10.1 with the following additional information:

1. Time after reactor shutdown;

' . The plant stack high range monitor response;

3. The plant stack flow rate at the time of the accident; and

4. Wind speed.

The assumptions incorporated in and the use of the nomograms contained in Figure 10.1, are discussed in Appendix C.

In order to qualitatively define plume width, a transparent overlay has been prepared for a Vermont area base map. The transparency consists of three angles; one angle each for unstable (Pasquill A, B, C stability classes), neutral (Pasquill D stability class) , and stable (Pasquill E, F G 'stability classes)'drawn from the plant out to a distance of ten'miles. Included within e'ach angle are areas lateral to the plume centerline having' radionuclide concentrations of at 5% of the plume centerline value. Centering the stability-dependent angles over the appropriate downwind direction on the site area base map qualitatively defines the plume width. The validity of this methodology is based on the assumption that meteorological conditions remain constant throughout the release.

Emergency Plan Revision 39 Page 79 of 166 Entergy Vermont Yankee

10.1.2. Variable Trajectory Atmospheric Dispersion/Dose Projection Capability Once the EOF/RC is activated, Vermont Yankee utilizes a plume tracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiological accident conditions. The system assumes a Gaussian, variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power.

Station site. Both continuous and intermittent releases for either ground or stack release points can be evaluated. The effects of release height, building wake entrainment, momentum plume rise, precipitation and terrain height can be assessed in the evaluation. Plume trajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.

The model combines complex plume transport algorithms with the same dose assessment algorithms used by the model described in Section 10.1.1. The model is programmed on a personal computer. The program is designed to graphically display the calculated plume characteristics on a 10-mile Vermont Yankee EPZ site map while providing transcripts of all dispersion and dose calculations.

10.1.3. Evaluation of Offsite Air Samples Vermont Yankee monitoring teams, after determining the location of the plume centerline (i.e.,

maximum radiation level) in the field, take air samples at various intervals downwind from the plant. These samples are analyzed for gross beta/gamma activity in the field and, if elevated levels are observed, they are returned to the Emergency Operations Facility where they are analyzed to determine radionuclide concentrations. These field results can be projected to other distances of interest.

Particular attention is given to observed iodine concentrations. Air samples are analyzed in a multi-step process. The first step involves field analysis of the sample which measures the gross radioactivity collected in the silver zeolite cartridge and filter paper using a pancake GM detector. Ifthe silver zeolite sample analysis shows a net count rate greater than the background count rate, the sample is immediately delivered to the EOF/RC for analysis with greater sensitivity and accuracy (for 1-131 specifically).

The projected thyroid dose is determined from the measured 1-131 concentration by multiplying the estimate of the duration of exposure by the dose conversion factor for an adult member of the public. A nomogram has been developed specifically for this thyroid dose projection on the basis of airborne radioiodine.measurements. It is shown in Figure 10.2.

In addition to the measurement and evaluation' of offsite direct dose rates and air samples for radioiodine, the offsite radiological impact assessment includes the identification of principal radionuclides potentially released from the accident and significant exposure pathways.

This is accomplished through an emergency sampling program in which environmental samples of media (water, air, soil, etc., as appropriate) are collected and subjected to detailed radionuclide analysis. The necessary analysis can be performed by the mobile laboratory when it arrives at the EOF/RC, and at the laboratory in Westboro.

Emergency Plan Revision 39 Page 80 of 166 Entergy Vermont Yankee

10.2. Protective Action Rec6mmendation Criteria In the event a General Emergency has been declared, Vermont Yankee immediately recommends protective actions to state authorities based on plant conditions which include the status of core and containment conditions.. At a minimum, the Plant Emergency Director, Technical Support Center Coordinator, or Site Recovery Manager, who is in charge of the emergency. response activities, recommends that the general public be advised to seek shelter for the towns of Hinsdale, New Hampshire and Vernon, Vermont;'and the towns located five miles downwind in the affected sectors.

If plant conditions indicate a severe reactor accident exists involving actual or projected substantial core damage, the Vermont Yankee recommends to the appropriate state officials evacuation of the towns of Hinsdale, New Hampshire and Vernon, Vermont; and all towns located five miles downwind in the affected sectors.

With an emergency condition producing'a radiological release or an implant (i.e., containment) source term that could be subsequently released, one of the priorities of the responding emergency personnel is to implement the sampling and analysis of releases and/or source terms to identify if there is a radioiodine component. This sampling capability includes containment atmosphere, gas spaces in other plant systems, and the plant stack. Radioiodine identified at any of these points are quantified and evaluated in terms of actual or potential offsite impact.

Once actual source term, onsite and/or offsite field monitoring determinations have been made, Vermont Yankee Site Recovery Manager or desigbee provides projected offsite Total Effective Dose Equivalent's'(TEDEs) and thyroid Committed Dose Equivalents (CDEs)'at various distances from the plant to the Departments of Public Health of Vermont, New Hampshire and Massachusetts. Based upon these results, the Site Recovery manager recommends protective actions in accordance with the criteria set forth in the EPA Protective Action Guides, Table 10.1.1. For environmental samples collected and analyzed by Vermont Yankee, the results of these samples are coordinated with the appropriate state agencies, and the state agencies implements the appropriate ingestion pathway protective actions in accordance with the FDA/HHS document Accidental Radioactive Contamination of Human Food and Animal Feeds, issued 8/13198. Table 10.1.2 lists the Recommended Derived Intervention Level (DIL) for each radionuclide group.

Emergency Plan Revision 39 Page 81 of 166 Entergy Vermont Yankee

10.3. Radiological Exposure Control During a plant emergency, abnormally high levels of radiation and/or radioactivity may be encountered. These levels may range form slightly above those experienced during normal plant operation to life-endangering levels of several hundred rem in a short period of time.

Under all emergency situations, immediate actions are required to regain control of the emergency or for life-saving purposes, steps should be taken to minimize personnel exposure from external and/or internal sources of radiation.

Table 10.2 specifies the guidelines on emergency dose limits for personnel providing emergency response duties which is consistent with the Environmental Protection Agency Emergency Worker Dose Limit Guides (EPA 400-R-92-001). The Shift Supervisor/Plant Emergency Director initially has the responsibility to authorize emergency dose commitments until relieved by the TSC Coordinator. This authorization is coordinated with the assistance of the Radiation Protection Supt. or Shift Chemistry and Radiation Protection Technicians as needed. Exposure to individuals providing emergency functions will be consistent with the limits specified in Table 10.2 with every attempt made to keep exposures ALARA.

The Radiation Protection Supt. is responsible for developing emergency radiological protection programs for plant staff support personnel. Emergency kits in each emergency center are provided with self-reading dosimeters (both high and low range). Each member reporting to the site will be provided a TLD badge. Dose records will be maintained at each center based upon the results of the self-reading dosimeters. This information is cross-referenced with the TLD badge data, as soon as they can be processed at the Emergency Operations Facility/Recovery Center, or the'Environmental Lab in Westboro, Massachusetts. The' Environmental Lab provides a supply of TLD badges to the plant. Processing of the TLD badges results in a turnover rate of about 20 badges per hour. Based on the extent of the emergency supplies and the radiological conditions, responding offsite authorities are provided dosimetry if they require it.

10.4. Protective Measures 10.4.1. Site Personnel Accountability The goal of the personnel accountability process is to account for personnel within 30 minutes of the emergency declaration. Plant procedures require Security personnel at the gate to maintain a list of personnel entering or leaving the site during a site evacuation. Emergency Response Facility Coordinators are responsible for accounting for-their staff as they report to their facility. Each facility maintains an organizational sign-in method which enhances this reporting process. All reports are provided to the TSC Coordinator in the Technical Support Center, who initiates search and rescue actions for any missing personnel. Plant security provides assistance for this accountability effort and aids in the control of personnel during extended emergency operations.

Accountability may be modified or suspended if the safety of personnel may be jeopardized by a Security event or other event hazardous to personnel.

Emergency Plan Revision 39 Page 82 of 166 Entergy Vermont Yankee

10.4.2. Site Egress Control Methods 2 All visitors and contractors are evacuated from the plant under the Alert, Site Area or General Emergency conditions. At the Site Area or General Emergency all visitors and contractors are directed to report to the EOF/RC for monitoring. Emergency personnel assigned to the EOF/RC and other unassigned plant personnel, report immediately to the EOF/RC, and are monitored upon arrival at the facility. If a Code Red Security event has been declared, evacuation and accountability may put personnel at risk. In these security situations, evacuation and accountability may be suspended until directed by Security.

Plant evacuees are advised of area evacuation routes prior to being released. Appendix F provides evacuation time estimates for the plume exposure EPZ, and also details the major evacuation routes that.could be used in the area. Access to the plant is not allowed unless personnel are specifically authorized.

10.4.3. Decontamination Capability The in-plant decontamination facility is located in the Operations Support Center. Waste generated through the use of this system is collected and processed by the plant liquid radwaste system. Survey instrumentation for personnel "frisking" and sensitive body burden monitoring equipment are available in various plant locations.

Decontamination at the EOF/RC is provided by using washcloths, which are disposed of by

.placing them in a 55-gallon drum. If conditions warrant alternative means, the EOF/RC has emergency decontamination capability (decontamination shower with the waste draining in to a L holding tank)' After accident conditions have been terminated, the holding tank is sampled to ascertain whether abnormal radiological levels exist. Depending upon the activity present and the isotopic determination, plans will be developed to remove the waste for disposal.

10.4.4. Use of Onsite Protective Equipment and Supplies The plant supplies of personnel radiation protection equipment and gear are utilized to support the emergency response effort. Equipment such as respiratory protection gear, all types of protective clothing, and a supply of potassium iodine is assigned to emergency response organization members in accordance with established plant radiation protection criteria.

Radiation guideline acti6n levels for a range of plant radiological conditions are shown in Table 10.3.

10.4.5. Fire Protection Equipment The plant maintains sufficient respiratory equipment (i.e., Scott Air Pacs and spare air cylinders), to support emergency response personnel in the event of a fire. Additionally, Vermont Yankee maintains a letter of agreement with the Brattleboro Fire Department for recharging Scott Air Pac cylinders during an emergency.

Emergency Plan Revision 39 Page 83 of 166 Entergy Vermont Yankee

10.5. Aid to Affected Personnel 10.5.1. Medical Treatment In-plant medical supplies are provided in the Operations Support Center. Medical Response Team members are trained in accordance with OP 3712.

Arrangements exist with the hospitals indicated in Section 8.4.1. Both hospitals participate in medical emergency drills. Figure 10.3 shows hospitals within the ingestion exposure EPZ of Vermont Yankee, which have the capability to handle radiation emergencies.

10.5.2. Medical Transportation Arrangements exist with Rescue, Inc., to provide 24-hour ambulance service for emergency transportation of plant personnel for offsite treatment. The ambulance service is capable of radio communications with the hospital while en route with a patient. Normal telecommunication channels are used in notifying the ambulance service dispatch center.

Rescue, Inc. personnel are provided with specific training by Vermont Yankee on the health physics considerations associated with radioactively contaminated personnel and site access control measures.

.i . .

. . I Emergency Plan Revision 39 Page 84 of 166 Entergy Vermont Yankee

TABLE 10.1.1 EPA PROTECTIVE ACTION GUIDELINES Total Effective Dose Committed Dose Equivalent Protective Action Equivalent (TEDE (CDE) to the Thyroid

>1 rem >5 rem EVACUATION (Sheltering may be preferred protective action if the following are present:

. Severe weather,

• Competing disasters,

• Local physical factors which impede evacuation LOCAL/STATE OFFSITE OFFICIALS WILL DETERMINE THE SIGNIFICANCE OF THESE FACTORS TO THE PAR SUBSEQENT TO THE ISSUANCE OF THE PAR BY VY.)

Emergency Plan Revision 39 Page 85 of 166 Entergy Vermont Yankee

TABLE 10.1.2 RECOMMENDED DERIVED INTERVENTION LEVEL (DIL)

OR CRITERION FOR EACH RADIONUCLIDE GROUP(a)(b)

All Components Of The Diet Radionuclide Group (Bg/kg) (pCi/kg)

Sr-90 160 4300 1-131 170 4600 Cs-1 34 + Cs-1 37 1200 32,000 Pu-238 + Pu-239 + Am-241 2 54 Ru-1 03 + Ru-106(c) 03 + C6 <1 03 + A 6 <1 6800 450 180,000 12,000 Notes:

(a) The DIL for each radionuclide group (except for Ru-103 + Ru-106) is applied independently. Each DIL applies to the sum of the concentrations of the radionuclides in the group at the time of measurement, (b) Applicable to foods as prepared for consumption. For dried or concentrated products such as powdered milk or concentrated juices, adjust by a factor appropriate to reconstitution, and assume the reconstitution water is not contaminated. For spices, which are consumed in very small quantities, use a dilution factor of 10.

(c) Due to the large difference in DILs for Ru-103 and Ru-106, the individual concentrations of Ru-103 and Ru-106 are divided by their respective DILs and then summed. The sum must be less than one. C3 and C6 are the concentrations, at the time of measurement, for Ru-1 03 and Ru-1 06, respectively.

(from Accidental radioactive Contamination of Human Food and Animal Feeds:

-.. Recommendations for State and Local Agencies, Table 2, 8/13198)

Emergency Plan Revision 39 Page 86 of 166 Entergy Vermont Yankee

TABLE 10.2 EMERGENCY DOSE LIMITS(a)

(refer to Notes I and 2)

Dose Limit (refer to Note 3) Work Activity Condition 5 Rem Total Effective Dose Maintain ALARA and to extent Equivalent (TEDE All practicable limit emergency workers to these limits 10 Rem TEDE Protecting Valuable Property Lower dose not practicable 25 Rem TEDE Lifesaving or Protection of Lower dose not practicable Lifesaving or Protection of Only on a voluntary basis to 75 Rem TEDE Larg opu on persons fully aware of the LargePopultionrisks involved NOTES:

1. For emergency dose limits the following considerations should be made:

a. Declared pregnant women will not be allowed to participate.

b. The use of volunteers for exposures during' emergency actions is desirable.

Older workers with low lifetime accumulated effective dose should be given priority.

c. The individual(s) awareness of biological consequences that such as exposure can have, including the risks associated with exposure of a developing embryo/fetus for female workers.

d. All practical protective measures to limit such an exposure.

e. Concurrence of individual(s) involved (i.e., voluntary risk acceptance).

f. The probability of success should be balanced against the expected exposure limit.

g. The individual's familiarity with the task and speed that the individual can conduct the task.

2. After the emergency has been concluded, doses received by emergency workers are required to be accounted for in accordance with 10 CFR Part 20 occupational dose limits.

3. Emergency dose limits for the lens of the eye and for any organ (including skin and extremities) are three and ten times the listed values, respectively.

a EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Revised 1991 Emergency Plan Revision 39 Page 87 of 166 Entergy Vermont Yankee

TABLE 10.3 EMERGENCY CENTER HABITABILITY AND PROECTIVE ACTION CRITERIA 1.. A background dose rate of 50 mRem/hr will increase the frequency of radiation monitoring in the center and require an immediate evaluation of the accumulated TEDE at the affected center.

2. A reading of I Rem on the high-range or alarming dosimeter will initiate planning for possible evacuation to the alternate center.

a) Ifthe TSC has to be evacuated,

1) The TSC Coordinator and immediate staff deemed necessary to deal with the emergency should relocate to the Control Room and continue their respective roles in the Emergency Response Organization.

2) Remaining TSC staff should relocate to the EOF/RC in support of their respective disciplines or be otherwise reassigned by the manpower &

Planning Assistant.

b) Ifthe OSC has to be evacuated, the TSC will determine an alternate area for

-relocation.

3. A reading of 4 Rem on the high-range or alarming dosimeter will initiate evaluation of the need for a phased evacuation.

4. Ifcenter personnel have been or may be exposed to elevated radioiodine air concentrations in excess of 500 millirem/hr (4.0 x 104 microcuries/cc), evaluate the need for administration of KI for center staff and relief shift personnel.

. i .

Emergency Plan Revision 39 Page 88 of 166 Entergy Vermont Yankee

C C C OFFSITE DOSE RATE AT 11 WLE (mrsmtfr)

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II I RELEASERATEFUNCTION.JCt) M NOBLE.As I OFFSITE DOSE RATE FUNCTION - - N6OLE OAS 10' t UN 1 F CTI N DOSE 1 RATE .0 _ _ _ _ _E__

~STACK HIGHIR M NIO I WIND SPEED TIMES GAMMA DIFFUSION llME1A10R S0HUTDO (0 FACTOR AT 13 MILE t2.0 x 104 mete TIME AFTER SHUTDOWN (HOURS) (IDEPENDENT OF STABILMY CLASS)

Figure 10.1 Vermont Yankee Emergency Dose Rate Nomogram Emergency Plan Revision 39 Page 89 of 166 Entergy Vermont Yankee

100000 100HR 10000 50 HR 20 HR 3-1000 8HR 4 HR 2HR

- 100 IHR LU n

C)

W 9

¢S

• 1.OO .-l 1.OOE-08 1.00E-07 1.00E^06 .1.OOE-05 ,1.OOE.04 1-131 Air Concentration (uCilcc) .

Figure 10.2 Field Sample Thyroid Dose Nomogram Emergency Plan Revision 39 Page 90 of 166 Entergy Vermont Yankee

NWNWEMM N ' /

a- -, GRAFTON S It. VT I. I VARREN  : , I ** , ,* * *. o

• * ' 50 I lSULLIYAN . . _., _ .~

II I.

• 50 MLAscutneyHosp.' NHI RUTLAND * + Windsor '

• I

,, ' (MERRIMACK II' - WMNDSOR Sptrngfield Hasp.,

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.. '* . f Rockingham Memorial Hosp. . - * -

1 BENNINGTON ROcklngham ' -. - -

Grace Cottage Hosp.

SARATOGA

/ , Townshend INDHAM Cheshire Medical Center Keene

.a..-

I. I _. HILLSBORC

. .. . .. - - Bns~oO~ollop/CHESHIRE Brattleboro Menmdral Hasp. CEHR l + 8r ttleborom Putnam Memorbal ttYan Vemn

,'> : "^ Bennington Yankee >

. W--... -a.'

• North Adams Hosp. -

g '. t iNorthAdams , FRANKLIN

• I ..

a I e Frnkln MedicalCenter Greenfneld WORCESTER p-.... - - - , BERKSHIRE , , , -,

NY+ s- HAMPSHIRE a' N

Brkshire Medical Care ' ,*,' + Cooley Dickson Hos',

Q Pittstleld a+ Yr 444., * -.-Northampton.

'* ' ' - 't~ 8state Medical Cnter COLUMBIA SpringIeld

. I S.

CT HARTFORD  :'TOLLA DUTCHESS LITCHFIELD H ,TOLLAND WINDHAM RI

. '- I 0 10 20 30 40 50

. _ I.

Miles C Hospital can handle contaminated patients.

• - Figure 10.3 .*..*  :

Medical Facilities within 50 Miles of Vermont Yankee Capable of Handling Emergency Medical Cases Emergency Plan Revision 39 Page 91 of 166 Entergy Vermont Yankee

11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 11.1. Emergence Notification The Plant Emergency Director is responsible for the notification of the State Police of Vermont, New Hampshire, and Massachusetts. Notification is made within 15 minutes of emergency classification and is the initial link to offsite authorities for the activation of offsite emergency response plans, which includes emergency public notification if the emergency conditions warrant.

The format and contents of the initial message between the plant and State Police dispatchers are specified in notification procedures and have been established with the review and agreement of those state authorities responsible for state plans.

As soon as contacted via the notification fan-out procedure, the Department of Public Health of Vermont, Massachusetts and New Hampshire call Vermont Yankee and may request the following information:

1. Date, time and class of the emergency;

2. Type and quantity of release, height of release, and estimated duration/impact times;

3. Prevailing weather conditions (wind velocity, direction, temperature, atmospheric stability, form of precipitation, if any);

J

4. Actual or projected dose rates at .35 miles from the site, and projected dose rates at various distances from the plant;

5. Emergency response actions underway; and

6. Recommended protective actions.

These follow-up reports are provided on an as-needed basis until such time that the emergency condition has been terminated in agreement with the States of Vermont and New Hampshire, Commonwealth of Massachusetts, and Vermont Yankee plant management.

11.2. Public Notification The prompt public notification methods in the Vermont Yankee area utilize, radio, television, sirens and weather alert receivers, police and fire department mobile loudhailers and sirens, and door-to-door notification should that be required. Details of this system are provided in Appendix H.

Emergency Plan Revision 39 Page 92 of 166 Entergy Vermont Yankee

11.3. Public Information Any emergency generates a continuous and intensive demand for up-to-date information. This is best accomplished if each organization involved is aware of what the others are saying.

Consequently, Vermont Yankee has planned for the establishment of a Joint News Center for the purpose of providing coordinated press releases during an accident.

For an Unusual Event, the Director of Public Affairs is notified of the incident by telephone or paging system. The Director of Public Affairs, or designated alternate, is responsible for writing any official statements or press releases concerning the incident. Prior to release, statements are approved by an officer of the company or designee. Information is released directly to the press pool and the "Status Phones" are updated with this information. In addition, the Director of Public Affairs notifies the appropriate departmental staff and activates the corporate public affairs office.

For an Alert, the actions taken under an Unusual Event are followed with press briefings (optional) conducted by the Director of Public Affairs or designated alternate. A determination is made as to whether media interest requires the activation of the Joint News Center. In addition, the Media Advisor reports to the EOF/RC and is responsible for conveying all information on plant conditions to the Joint News Center.

For a Site Area Emergency and a General emergency, the Joint News Center is activated and fully staffed.

The Media Advisor and required staff report to the EOF/RC for coordinating the accident information between the plant and the Joint News Center; 'The Joint News Center is staffed and provides immediate accessibility to information files and resources for the Nuclear Information Director (Director of Public Affairs, or designated alternate) and/or the Joint News Center staff.

Regular press conferences are held at the Joint News Center, directed by the Nuclear Information Director in conjunction with appropriate state and federal organizations. Vermont Yankee's Public Affairs can provide 24-hour coverage at the Joint News Center to ensure timely updates and answers to questions from visiting media representatives.

As part of Vermont Yankee's full disclosure policy, Vermont Yankee has initiated a public inquiry phone for media and public use. Normally, a prerecorded message provides, on a daily basis, routine operating information, changes'in plant operfation,' and other items of interest. -'

During an emergency, the phone is used to relay and provide .up-to-date status reports' regarding the situation.

Joint News Center personnel monitor local radio and television for erroneous information concerning accident conditions. When misinformation is recognized, corrective action is taken.

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Communication is provided between the Joint News Center and the EOF/RC and for state and federal agency use. Public information documentation covering the following areas of concern is available:

1. Educational information on radiation;

2. Educational information on the Vermont Yankee Nuclear Power Plant;

3. The emergency Classification System and notification process; and

4. Planned protective actions to be implemented by state and local authorities.

Vermont Yankee assists the States of Vermont and New Hampshire and the Commonwealth of Massachusetts, to develop and ensure for dissemination on a yearly basis, brochures, calendars, and posters which provide the public with emergency planning arrangements.

The Vermont Yankee Public Affairs Department conducts annual information programs to acquaint the news media with information concerning radiation, emergency public information procedures, the emergency Classification System and a general review of plant characteristics. Local and state media are invited and encouraged to attend.

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12.0 MAINTAINING EMERGENCY PREPAREDNESS 12.1. Drills and Exercises An exercise tests the execution of the overall plant emergency preparedness and the integration of this preparedness with offsite authorities. Adil is a supervised instruction period aimed at testing, developing and maintaining skills in a particular response function.

Emergency exercises and drills are conducted to test and evaluate the adequacy of emergency facilities, equipment, procedures, communication channels, actions of emergency response personnel, and coordination between offsite agencies and the facility.

A summary of exercises and drills and associated elements is outlined below.

12.1.1. Radiation Emergency Drills and Exercises A full participation exercise shall be conducted every two years. At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between biennial exercises. State and offsite agencies may participate in drills.

12.1.2. Communication Tests To ensure that emergency communications between the facility and offsite emergency rsonse organizationsaare operable. communications tests aecnutda ulndblw Items 2) and 3) below can be performed as part of an Emergency plan drill or exercise.

1. Communication channels'with state governments within the plume exposure pathway are tested monthly;

2. Communications with state Emergency Operations Center (EOCs) are conducted annually;

3. Communications with assessment teams are conducted annually;

4. Communications among states within the ingestion pathway are tested monthly; and

-5. Communications with the NRC Region I Office from the Control Room, TSC and EOF are tested monthly.

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To ensure the reliability of the plant's call-in procedure, the following test/drill is performed as 2> follows:

Weekly functional test of the pager system to selectively test pager performance, and Annual off-hours, unannounced communications drill, utilizing both the pager system and commercial telephone, to estimate emergency personnel response times.

12.1.3. Fire Drills To test and evaluate the response and training of the plant's fire brigade, a number of fire drills are conducted annually.

To demonstrate the coordination between the plant's fire brigade and the Vernon Fire Department, the fire department is annually offered the opportunity to participate in an onsite fire drill.

12.1.4. Medical Drills To evaluate the training of the facility's medical response team and offsite medical response (ambulance and hospital), a medical drill is conducted annually with a simulated contaminated injured individual. This drill can-be performed as part of an Emergency Plan drill or exercise.

12.1.5. Radiological Monitoring Drills Plant environs and radiological monitoring drills (onsite and offsite) are conducted annually.

These drills include collection and analysis of airborne sample media, communications, record keeping, and interface with offsite monitoring efforts. This drill can be performed as part of an Emergency Plan drill or exercise. Radiological monitoring drills will include interface with State offsite monitoring efforts during the biennial exercise.

12.1.6. Health Physics Drills Health Physics drills are conducted semi-annually involving response to, and analysis of, simulated elevated in-plant airborne and liquid samples and direct radiation measurements in the environment. A drill can be performed as part of an Emergenci Plan drill or exercise.

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12.1.7. Scenarios An Exercise/Drill Coordinator, is responsible for an emergency plan drill or exercise. The Exercise/Drill Coordinator's responsibilities include developing the exercise/drill scenario, the accident time sequence, and the selection and training of the Controllers required to evaluate the effectiveness of the Vermont Yankee Emergency Preparedness Program.

A scenario is prepared by the Scenario Development Group for'each exercise/drill to be conducted. The scenario varies year to year and is approved by Vermont Yankee Management. Within a six-year period, the scenario content is varied to test all the major elements of the Emergency Plan Program. For full participation exercises, the scenario simulates an emergency condition and sequence that calls for the mobilization of the offsite authorities; requires the recommendation of offsite protective actions; and allows for the evaluation of offsite plans and integration with the plant response.

The contents of the scenario includes, but is not limited to, the following:

1. Basic objective(s);

2. Date, time period, place and participating organizations;

3. Simulation lists;

4. Time schedule of real and simulated initiating events;

5. A narrative summary describing the conduct of the exercise to include such items' as simulated casualties, search and rescue of personnel, deployment of radiological monitoring teams, and public information affairs; and

6. List of Controllers.

The scenarios are designed to allow free play in exercising the decision-making process associated with such emergency response actions as exposure control, emergency classification and de-escalation, protective action recommendation, and the emergency manpower augmentation process.

Security based scenarios to test and evaluate security response capabilities will be conducted in accordance with security drills and exercise procedures and may be conducted during emergency plan drills or exercises. -

Starting times and pre-notification for exercises are coordinated with and agreed upon by all participating organizations. The scenario package is submitted to the NRC in accordance with current regulatory guidance.

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12.1.8. Evaluation of Exercises To evaluate the performance of participating facility personnel and the adequacy of emergency facilities, equipment and procedures during an exercise, the Exercise Coordinator obtains qualified controllers which includes resources outside the facility to evaluate and critique the exercise.

When feasible, personnel designated as controllers are assigned to an Emergency Plan area germane to their area of expertise. Controllers are provided general instruction concerning their specific observation function. Each controller is requested to observe the implementation of the emergency plan element assigned to him or her, and then to record and report observed inadequacies.

A critique is conducted at the conclusion of the exercise with facility personnel as designated by the General Manager or a designated representative. After the critique, the controllers submit a written evaluation to the Exercise Coordinator in which the exercise performance is evaluated against the objectives. All comments and/or recommendations are documented.

Controllers from State Emergency Management and Health Department agencies are encouraged to join the observation and critique process.

Weaknesses and/or deficiencies identified in an exercise critique are processed in accordance with the site corrective actions program.

12.1.9.: Emergency Plan Audit The Vermont Yankee Emergency Plan is independently audited as part of the Vermont Yankee In-plant Audit Program. The audit is conducted as part of the Vermont Yankee Quality Assurance Program in accordance with 10 CFR 50.54(t). All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.

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12.2. Training All non-essential plant personnel receive annual instruction, in accordance with "Emergency Plan Training" (OP 3712), concerning their expected response action during an emergency.

Those members of the plant staff who have been assigned (per the Emergency Assistance Personnel List) to the emergency response organization receive annual training which includes, but is not limited to, the following:'

1. Familiarize individuals with Emergency Plan and implementing procedures, especially where emergency response tasks are not part of their normal duties;

2. Define an individual's responsibilities associated with their designated function;

3. Familiarize individuals in emergency exposure control measures and guidelines, particularly those associated with an individual's designated emergency functions; and

4. Provide sufficient technical insight to maintain emergency functions.

A portion of this training is provided by personnel's participation in unrehearsed drills or emergency exercises. During these drills and exercises, controllers check the performance of the personnel assigned, and provide critiques which could be incorporated in future training.

Specific details of the training given on an annual basis are described in OP 3712, "Emergency Plan Training", and in the Emergency Plan Training Program Description.

12.3. Review and Updating of Plan and Procedures The Emergency Plan is reviewed at least annually and the associated implementing procedures are reviewed at least biennially. All recommendations for changes to the Emergency Plan or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q). The Emergency Plan is submitted to Vermont Yankee's Plant Operations Review Committee for approval. Written agreements with outside support organizations and government agencies are evaluated prior to any emergency plan exerciseldrill and/or planned medical, fire, or security drills to determine if these agreements are still valid. If agreements are not valid, then they are renewed and updated. This agreement review is documented.

Revisions to the Emergency Plan are made in accordance with current regulations and guidelines.. Changes to the Plan are forwarded to organization and individuals with a responsibility for implementation of the Plan. Telephone number listings associated with the.,

emergency notification process are updated quarterly. -

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12.4. Maintenance and Inventory of Emeriency Equipment and Supplies The emergency equipment maintained in the Control Room, Operations Support Center, Technical Support Center, and the Emergency Operations Facility are listed in a checklist in implementing procedure OP 3506, Emergency Equipment Readiness Check, that is used to check readiness.

Weekly, the Operations Department conducts a test of certain emergency communications equipment. At least quarterly in accordance with the emergency equipment inventory procedure, and subsequent to each usage, Radiation Protection Department, Chemistry Department, and other designated VY personnel are assigned to inventory and maintain the emergency kits and/or equipment. Rotation of survey instruments normally used in the plant with instruments in the Emergency Kits assures that emergency equipment is calibrated and fully operable. There are sufficient reserve instruments and equipment to replace those that are removed from emergency kits for calibration purposes. Appendix B contains a list of emergency equipment by location.

12.5. Responsibility for the Planning Effort The Senior Operations Executive has overall responsibility for implementation of the Emergency Plan at Vermont Yankee. The Emergency Planning Manager is responsible for emergency planning and the interface with local and state governments. The Emergency Planning Manager reports offsite to the Director, Emergency Programs. The duties of the Emergency Planning Manager include, but are not limited to, the following:

1. Revise and update the Emergency Plan;

2. Maintain the Emergency Plan implementing procedures so that they are updated and current with the Emergency Plan;

3. Schedule and ensure the conduct of emergency equipment inventories and calibration;

4. Represent the plant in state and local Emergency plan interfaces;

5. Represent the plant in NRC emergency planning appraisals and audits;

6. Interface with the Exercise Coordinator in preparing and coordinating Emergency Plan drills and exercise; and

7. Maintain drill and exercise documentation and coordinate implementation of corrective actions deemed necessary following drills and exercises.

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APPENDIX A EMERGENCY CLASSIFICATION SYSTEM IAND  :

EMERGENCY ACTION LEVELS

[NOTE: The next page (AP 3125 EAL Chart) is not numbered, but should be considered the next consecutive page in this document.]

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APPENDIX B EMERGENCY EQUIPMENT This Appendix contains a list of emergency equipment by location. Backup equipment is available at the Radiation Protection control point and associated areas located in the OSC. In addition, all the resources of the Environmental Lab in Westboro, MA are at the disposal of Vermont Yankee in an emergency.

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APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATION MAIN TECH OPS OUTER INNER

CONTROL SUPPORT SUPPORT GATE GATE EQUIPMENT ROOM CENTER CENTER EQF/RC HOUSE HOUSE*

Respiratory Protection Radiation Monitoring Dosimetry Sampling Communications . .

Dose Assessment Area Map/Status Boards .

NomogramlArea Map .

Emergency . .

References Protective Clothing .

Decontamination Barrel .. ._._._-_._.

Administrative Support Status Boards Coolant Sampling Containment Air Sampling Stack Sampling Sampling Cartridges Portable Lead Shielding Emergency Centers & . .

Emergency Room . .

Keys -

Station Sampling Cartridges .

Environmental Station Keys KI (A more detailed listinig of emergency equipment is provided in OP 3506, "Emergency Equipment Readiness Check")

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APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATION EQUIPMENT MOBILE ENVIRONMENTAL COUNTING LABORATORY Gamma Spectroscopy High Pressure Ion Chamber Mobile Processing TLD Unit Personnel &

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APPENDIX C

..- INITIAL OFFSITE DOSE RATE ESTIMATION

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APPENDIX C (Continued)

Vermont Yankee has developed a method to quickly determine the release rate and the 2 projected offsite dose rate at 1/3 mile from the site that could be associated with an accident condition that exceeds the range of the normal plant stack Radiation Monitoring System. This determination is made by using figure 10.1 with the following input variables:

1- . Time after reactor shutdown;

2. The plant stack high-range monitor response;

3. The plant stack flow rate at the time of the accident; and

4. Wind speed The plant stack high range monitor consists of a Victoreen ion chamber located at the base of the stack (el. 264') and shielded by 1/2" of aluminum. A release rate function, J, has been determined at this location for a fuel melt mixture of fission product noble gases, as a function of time after reactor shutdown. This function, J, converts the monitor response to total activity concentration in the stack.

The activity release rate is determined from the nomogram, Figure 10.1, with the definition of the necessary input parameters. The projected offsite plume centerline dose rate at 1/3 mile from the stack can be determined from the nomogram once the following parameters are available: the response of the plant stack high range monitor, the plant stack flow rate , and the wind speed. The Offsite Dose Rate Function must be entered from the "time after shutdown" axis in order to obtain this result. The Offsite Dose Rate Conversion Function is the ratio of Parameter J to Parameter f at any time, t, where Parameter f is the effective dose conversion factor for the fission product noble gas mixture at time, t.

Atmospheric stability is not required due to the fact that the gamma dose diffusion factor does not vary significantly at 1/3 mile for a stack release. The value chosen for the nomogram is conservative for all atmospheric stability classes.

The dose rate determined by the nomogram provides a conservative estimate of Total Effective Dose Equivalent (TEDE) for a stack release dominated by noble gases. Since the iodine to noble gas ratio for a stack release are both relatively low, the thyroid dose does not contribute significantly to the TEDE under these conditions.

In order to qualitatively define plume width, a transparent overlay has been prepared for a Vermont area base map. The transparency consists of three angles [one each for unstable

.(Pasquill A, B, C stability classes), neutral (Pasquill D stability), and stable (Pasquill E, F, G stability) conditions]'drawn from the plant out to a distance of ten miles. 'Included within each angle are areas lateral to the'plume centerline having radionuclide concentrations of at 5% of the plume centerline value. Centering the stability-dependent angles over the appropriate downwind direction on the site area base map qualitatively defines the plume width. Using the appropriate sector/zone designation appropriate to the plume width, Vermont Yankee can provide the state authorities with an affected area.

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APPENDIX D ENVIRONMENTAL LABORATORY ANALYTICAL K) AND DOSIMETRY SERVICES' Emergency Plan Revision 39 Page 108 of 166 Entergy Vermont Yankee

APPENDIX D (Continued)

General The Environmental Laboratory in Westboro, Massachusetts, is equipped to provide radiochemical processing of all types of environmental media sampled as part of each participating plant's ongoing off-site environmental radiation surveillance programs. In the.

event of a radiological emergency at any participating plant, Laboratory staff are available, on a 24-hour emergency call basis, to perform gamma isotopic analyses on samples taken by the plant's emergency monitoring teams. In addition to the availability of gamma spectrometers'at the Laboratory, a portable gamma spectroscopy system can be deployed to a plant site to determine the presence and level of contamination in samples of various media in the event of an accidental release of radioactive material. In addition to the analytical capabilities in the area of environmental surveillance, the Laboratory maintains a large scale environmental and personnel Dosimetry processing operation in support of participating plants. Within hours of notification, a complete Dosimetry processing system can be fully operational at a remote site for immediate turnaround of environmental and personnel Dosimetry from plant staff and emergency sampling teams.

Portable Emergency Analysis Equipment Portable analysis equipment employed during an emergency response includes a shielded HPGe detector based gamma spectroscopy system complete with computerized spectral analysis capability. The system generates a report of plant-related nuclide concentrations, standard deviation, and Minimum Detectable Concentration (MDC) which is forwarded to assessment personnel.

A four-wheel drive company vehicle is maintained at the Environmental Laboratory in Westboro and is used to transport required equipment. Following a request from a plant for assistance in assessing an emergency condition, laboratory personnel will be dispatched to a designated location within four hours. Upon arrival, laboratory personnel will determine the presence and level of contamination in samples of various media (air cartridges, air filters, vegetation, water) collected by Plant Field Sampling Teams.

Emergency TLD Services During an emergency, one of the fully-automated TLD processing systems operated at the Westboro Laboratory can be transported to the Emergency Operations Facility.(EOF), or other remote location to allow a faster turnaround of personnel and environmental Dosimetry.

During an emergency, additional TLDs can be prepared by laboratory personnel. Remote site emergency TLD processing can be fully operational within twelve hours of a request.

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APPENDIX D (Continued)

Portable Body Burden Service The Environmental Laboratory is prepared to provide whole body counts (WBC) for emergency workers. Although the WBC System is considered portable, it requires setup in a permanent remote location with the required power supply.

The WBC System is comprised of a portable shielded HPGe detector, interfaced to a PC-based ADCI/MCA and IBM compatible portable computer. The analytical methodology provides a whole body scan and identifies activity content of the lung, GI, and thyroid.

A result report is generated for those plant-related nuclides found to be present at the 99%

confidence level.

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APPENDIX E LETTERS OF AGREEMENT This Appendix contains copies of the letters of agreement in effect between Vermont Yankee and the offsite authorities and organizations.

Emergency Plan Revision 39 Page 111 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

TABLE OF CONTENTS

1. States of Vermont, Massachusetts and New Hampshire June 2, 2000

2. Franklin Medical Center June 2, 2000

3. National Weather Service (NOAA) June 2, 2000

4. Brattleboro Memorial Hospital June 2, 2000

5. Rescue, Inc. Ambulance Service June 2, 2000

6. Vernon Fire Department June 2, 2000

7. Brattleboro Fire Department June 2, 2000

8. Duke Engineering & Services December 4, 2001

9. Institute of Nuclear Power Operations September 24, 2003

10. Town of Vernon March 13, 2000

11. Yankee Nuclear Power Station December 18, 2001

12. Department of Energy June 3, 2002

13. Vermont Yankee Nuclear Power Corporation November 12, 2002

14. Law Enforcement *

• All letters of agreement from Local Law Enforcement Authorities as required by the Physical Security Plan are classified as Safeguards Information and as such are maintained by Security.

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APPENDIX E (Continued)

LETTER OF AGREEMENT IBETWEEN VERMONT YANKEE NUCLEAR POWER STATION AND TIM STATES OF VERMONT, MASSACUSETTS, AND NEW HAMPSHIRE I. . PURPOSE The purpose of this Letter of Agreement is to establish conditions regarding emergency planning, notification and emergency response activities should an event at the plant require Emergency Plan activation.

I1. DEFINITION A. Emergency Operations Facility (EOF) - A center established to coordinate the deployment of Utility emergency response personnel, to evaluate off-site accident conditions, and to maintain communications with off-site authorities.

B. EOF Coordinator - The EOF Coordinator is a staff member of the Utility who -is responsible for those elements conducted within the Emergency Operations Facility (E0F).

C. News Media Center-A centerdedicated to the news media for the purpose of conducting joint State, Federal and Utility news briefings concerning emergency conditions.

D. Site Recovery Manager - A member of the corporate office who is responsible for planning recovery actions.

E. State -The states of Vermont, Massachusetts, and New Hampshire.

F. Utility-Vermont Yankee Nuclear Power Station located in Vernon, Vermont.

G. 'Nuclear Alert System - A communication system for initial notification to the State of an incident at the Utility, and the means of communication between the State and Utility for exchange of information during the period of the incident.

-m. AGREEMENT The State and Utility agree to the following:

A. It is the Utility's duty and obligation to notify the three State Police agencies immediately or no later than 15 minutes after the event has been classified as either an Unusual Event, Alert; Site Area, or General Emergency. The initial notification shall be made, as specified in the Utility and State plans, by the Utility using the Nuclear Alert System.

Commercial telephone communications will be used as the redundant means. Additional information will be provided to the State representative returning the call to the Utility.

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APPENDIX E (Continued)

B. The Utility will notify the three State Police agencies no later than 15 minutes after an emergency condition has been observed but immediately terminated. Notification shall be made, as specified in the Utility and State plans, using the system identified in IteinA above.

C. When both the EOF and any State EOC have been activated, the Utility agrees to notify the State BOC's immediately after a decision has been reached by the Utility on ESCALATI0-N DE-ESCALATION RECOMMENDED PAG's. and/or TERMINATION OF THE EMERGENCY. The notification shall be made by the Utility using the NUCLEAR ALERT SYSTEM. Commercial telephone will be used as the redundant means.

D. De-escalation from an Emergency Classification level to the recovery phase or termination of the emergency will not be made without the specific concurrence of responsible officials at each State EOC. The Utility and State agree to continue using the established procedure for de-#scalation as delineated in Vermont Yankee's procedures.

E. The State agrees to having the State representatives at the EOF be the State representatives at the Recoveqy/Re-entry meeting conducted by the Utility at the EOF.

However, it must be recognized that these individuals are not decision makers.

F. The State agrees to notify the utility, via the Nuclear Alert System, as to any protective actions taken.

G. The three States agree to have the Utility terminate an "UNUSUAL EVENT' emergency

-without obtaining State concurrence. However, it is the Utility's obligation to notify the three State Police centers when they terminate the 'UNUSUAL EVENT.

H. The Utility and State shall exchange and coordinate Emergency Plan changes that pertain to those elements of interface prior to implementing the change. The Utility and State will coordinate the effective date of the changes.

I. The Utility shall provide space for at least three representatives from the State at the Emergency Operations Facility (EOF) and the News Media Center. Location of the EOF and News Media Center will be the responsibility of the Utility.

J. The Utility and the State agree to exchange all information (plant radiological releases, off-site radiological conditions and plant technical data) known and available for emergency evaluation.

K. The Utility shall'provide and maintain communications for the State in each of the centers listed in Item I above. The Nuclear Alert System will be used, to coordinate the activities between the State and Utility. Either the State or Utility can activate the system for any use as necessary. (Exception: Control Room may be contacted only in extreme circumstances.)

L. The EOF Coordinator or Site Recovery Manager will be the point of contact for State representatives arriving at the Emergency Operations Facility. Authorities and responsibilities of the State and Utility personnel will be as outlined in their respective Emergency Plans.

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APPENDIX E (Continued)

M. To maintain public confidence and to avoid public apprehension, information shall be released to the public as soon as possible and in a coordinated manner through the news media center, if activated.

N. The Utility and State agree to exchange Public Information Packets for review prior to

'disseminating the packets to the public.

0. The State Health Departments agree to the method established by the Utility in projecting off-site whole body dose rates for the plume phase. During the post plume (ingestion pathway) phase, generally recognized methods recommended by responsible federal agencies shall be used for projections.

P. In the event of a radiological Emergency, the Utility agrees to make the Duke Engineering and Services Environmental Labs located in Westboro, Massachusetts, available to the State for counting samples.

Q. An accident shall be deemed to have terminated when, in the agreement of both the State and Utility, there is no longer need for either consideration of further protective action or surveillance related to off-site protective action. Close out of emergency classification shall be as outlined in respective Emergency Plans.

R. The State of Vermont agrees to notify the State of New York (ingestion pathway zone) and coordinate off-site radiological consequences with same during any event that should occur at Vermont Yankee in the Classification of a Site or General Emergency condition.

S. The Utility and the State agree to coordinate in the maintenance, updating, and exercise of both Utility and State Emergency Plans, as required by Federal regulations or as required by operational considerations.

T. This agreement may be amended by subsequent agreement between the State(s) and the Utility.

U. Upon the effective date, this Letter of Agreement will supersede the previous Letter of Agreement signed between the State and the Utility dated January 4, 1999.

V. Upon the execution of the parties hereto, this agreement shall be effective as of the latest date written below.

WV. The Utility shall notify the State of Vermont within one hour of any plant event that does not constitute an emergency classification but is significant enough to have the utility issue a news release.

3/4J 4 AJAI CTOR DATE VERMONT EMERGENCY MANAGEMENT (VEM)

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APPENDIX E (Continued)

VFONT YANKEE VWUDUR PWER SITAIRN DAT . Uf Emergency Plan Revision 39 Page 116 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LETTER OF AGREEMENT BETWEEN VERMONT YANKEE NUCLEAR POWER STATION AND THE STATES OF VERMONT, MASSACHUSETTS, AND NEW HAMPSHIE I. PURPOSE The purpose of this Letter of Agreement is to establish conditions regarding emergency plaing, notification and emergency response activities should an event at the plant require Emergency Plan activation.

I. DEFINITI A. Emer encv Operations Facilitv MEOFM - A center established to coordinate the deployment of Utility emergency response personnel, to evaluate off-site accident conditions, and to maintain communications with off-site authorities.

B. EOF Coordinator- The EOF Coordinator is a staff member of the Utility who is responsible for those elements conducted within the Emergency Operations Facility (EOF).

C. News Media Center-A center dedicated to the news media for the purpose of conducting joint State, Federal and Utility news briefings concerning emergency conditions.

D. Site Recoverv MaNraaer - A member of the corporate office who is responsible for planning recovery actions.

E. State - The states of Vermont, Massachusetts; and New Hampshire.

F. Utility - Vermont Yankee Nuclear Power Station located in Vernon, Vermont.

G. Nuclear Alert System - A communication system for initial notification to the State of an incident at the Utility; and the means of communication between the State and Utility for exchange of information during the period of the incident.

mfl. AGREEMENT The State and Utility agree to the following:

A. It is the Utility's duty and obligation to notify the three State Police agencies immediately or no later than 15 minutes after the event has been classified as either an Unusual Event, Alert, Site Area. or General Emergency. The initial notification shall be made, as specified in the Utility and State plans, by the Utility using the Nuclear Alert System.

Commercial telephone communications will be used as the redundant means. Additional information will be provided to the State representative returning the call to the Utility.

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APPENDIX E (Continued)

B. The Utility will notify the ree State Police agencies no later hand15 minutes after an emnergnc=c condition has been observed but immediately terninaled Noiification shall be made, as specified in the Utility and State plans, using the system identified in IteuigA above.

C. When both the EOF and any Stote EOC have been activated, the Utility agrees to notify thea State BOC's immediately after a decision has beez reached by the Utility on ESCALATION DE-ESCALATON, RECOM DED PAG's, and/or TM AT1ION OF THE EMERGENCY. The notification shall be made by the Utility using the NUCLEAR ALERT SYSTEM. Commercial telephone will be used. as the redundant means.

D. De-escalation from an Emergency Classification level to the recovery phase or termination of the emergency uill not be made without the specific concurrence of responsible officials at each State EOC. The Utility and State agree to continue using the established procedure for dc-escalation as delineated in Vermont Yankees procedures.

E. The State agrees to having the State representatives at the EOF be the State representatives at the RecoveryfRe-entry meeting conducted by the Utility at the EOF.

However, it must be recognized that these individuals are not decision makers.

F. The State agrees to notify the utility, via the Nuclear Alert System, as to any protective actions taken.

G. The three States agree to have the Utility terminate an 'UNUSUAL EVENT' emergency without obtaining State concurrence. However, it is the Utility's obligation to notify the three State Police centers when they tirmainate the "UNUSUAL EVENT".

H. The Utility and State shall exchange and coordinate Emergency Plan changes that pertain to those elements of interface prior to implementing the change. The Utility and State will coordinate the effective date ofthe changes.

1. Ile Utility shall provide space for at least three representatives from the State at the Emergency Operations Facility (EOF) and the News Media Center. Location of the EOF and News Media Center will be the responsibility of the Utility.

J. TMe Utility and the State agree to exchange all information (plant radiological releases, off-site radiological conditions and plant technical data) known and available for emergency evaluation.

K. The Utility shall provide and iaintain communications for the State in each of the.

centers listed in Item I above. The Nuclear Alert System will be used to coordinate the activities between the State and Utility. Either the State or Utility can activate the system for any use as necessary. (Exception: Control Room may be contacted only in extreme circumstances.)

L. The EOF Coordinator or Site Recovery Manager will be the point of contact for State representatives arriving at the Emergency Operations Facility. Authorities and responsibilities of the State and Utility personnel will be as outlined in their respective Emergency Plans.

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APPENDIX E (Continued)

. To maintain public confidence and to avoid public apprehension, information shall be released to the public as soon as possible and in a coordinated manner through the news media center, if activated.

N. The Utility and State agree to exchange Public Information Packets for review prior to disseminating the packets to the public.

0. . The State Health Departments agree to the method established by the Utility in projecting off-site whole body dose rates.

P. In the event of a radiological Emergency, the Utility agrees to make the Duke Engineering and Services Environmental Labs located in Westboro, Massachusetts, available to the State for counting samples.

Q. An accident shall be deemed to have terminated when, in the agreement of both the State and Utility, there is no longer need for either consideration of further protective action or surveillance related to off-site protective action. Close out of emergency classification shall be as outlined in respective Emergency Plans.

R. 7he State of Vermont agrees to notify the State of New York (ingestion pathway zone) and coordinate off-site radiological consequences with same during any event that should occur at Vermont Yankee in the Classification of a Site or General Emergency condition.

S. The Utility and the State agree to coordinate in the maintenance, updating, and exercise of both Utility and State Emergency Plans, as required by Federal regulations or as required by operational considerations.

T. This agreement may be amended by subsequent agreement between the State(s) and the Utility.

U. Upon the effective date, this Letter of Agreement will supersede the previous Letter of Agreement signed between the State and the Utility dated January 4, 1999.

V. Upon the execution of the parties hereto, this agreement shall be effective as of the latest date written below.

3--0OO DIRECTOR(/ DATE MASSACHUSETTS EMERGENCY MANAGEMENT AGENCY (MEMA)

VERNMZ!YANKEE NIJCL-POWER STATION DATE Emergency Plan Revision 39 Page 119 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

• LETTER OF AGREEMENT BETWEEN VERMONT YANKEE NJCLEAR POWER STATION AND THE STATES OF VERMONT, MASSACHUSETrS, AND NEW HAMPSBIRE-1.PURPOSE The purpose of this Letter ofAgreement is to establish conditions regarding emergency planning, notification and emergency response activities should an event at the plant require Emergency Plan activation.

I. DEFINITION A. Emnerencv Operations Facility MO) - A center established to coordinate the deployment of Utility emergency response personnel, to evaluate offsite accident conditions, and to maintain communications with off-site authorities.

B. EOF Coordinator - The EOF Coordinator is a staff mernber of the Utility who is responsible for those elements conducted within the Emergency Operations Facility (EOF).

C. Jlews Media Center -A center dedicated to the newvs media for the purpose of conducting joint State. Federal and Utility news briefingsconcerning emergency conditions.

D. Site Recoverv Manazer - A member of the corporate office who is responsible for planning recovery actions.

E. State - The states of crmont. Massachusetts. and New Hampshire.

F.- ttilitv - Vermont Yankee Nuclear Power Station located in Vernon, Vermont.

G. Nuclear Alert System - A communication system for initial notification to the State of an incident at the Utility. and the means of communication between the State and Utility for exchange of information during the period of the incident.

III. AGREEMENT The State and Uility age to the Colloiving:

A. It is the Utility's duty and obligation to notify the three State Police agencies immediately or no later than 13 minutes after the event has been classified as either an Unusual Event.

Alert. Site Area. or General Emergency. The initial notification shall be nade. as specified in the Utility and State plans. by the Utility using the Nuclear Alert System.

Commercial telephone communications will be used as the redundant means. Additional information will be provided to the State representative returning the call to the Utility.

Emergency Plan Revision 39 Page 120 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

B. The Utility will votify the three State Police agencies no later than 15 minutes after an emergency condition has been observed but immediately terminated Notification shall be made, as specified in the Utility and State plans, using the system identified i' Iam A above.

C. When both the EOF and any State EOC have been activated, the Utility agrees to notify the State EOC's inmediately after a decision has been reached by the ..Tjtility on ESCALATION DE-ESCALATFON. RECOMMENED PAG's,' and/or TERh2NATON OF THE EMERGENCY. The notification shall be made by the Utility using the NUCLEAR ALERT SYSTEML Commercial telephone will be used. as the redundant means.

D. Dc-escalation from an Emergency Classification level to the recovery phase or termination of the emergency will not be nude without the specific concurrence of responsible officials at each State EOC. The Utility and State agree to continue using the established procedure for de-escalation as delineated in Vermont Yankee's procedures.

E. The State agrees to having the State representatives at the EOF be the State representatives at the Recovery/Re-entrv meeting conducted by the Utility at the EOF.

However, it must be recognized that these individuals ae not decision makers.

F. The State agrees to notifY' the utility, via the Nuclear Alert System, as to any protective actions taken.

G. The thret States agree to have the Utility terminate an 'UNUSUAL EVENT" emergency Without obtaining State concurrence. However, it is the Utility's obligation to notify the three State Police centers when they terninate the "UNUSUAL EVENT.

H. The Utility and State siall exchange and coordinate Emergency Plan changes that pertain to those elements of interface prior to implementing the change. The Utility and State will coordinate the lffective date of the changes.

I. The Utility shall provide space for at least three representatives from the State at the Emergency Operations Facility (EOF) and the Newvs Media Center. Location of the EOF and News Media Center will be the responsibility of the Utility.

J. The Utility and the State agree to exchange all information (plant radiological releases, off-site radiological conditions and plan( technical data) known and available for emergency evaluation.

K. The Utility shall provide and maintain communications for the State in each of the centers listed in Item I above. The'Nuclear Alert System will be used to coordinate the activities between the State and Utility. Either the State or Utility can activate the system for any use as necessary (Exception: Control Room may be contacted only in extreme circumstances.)

L. The EOF Coordinator or Site Recovery Marnger will be the point of contact for State representatives arriving at the Emergency Operations Facility. Authorities and responsibilities of the State and Utility personnel wvil be as outlined in their respective Emergency Plans.

Emergency Plan Revision 39 Page 121 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

M. To maintain public confidence and to avoid public apprbension, information shall be released to the public as soon as possible and in a coordinated mnanher through the news media center, if activated N. ne Utility and State agree to exchange Public Information Packets fbr review prior to disseminating the packets to the public.

0. The State Health Departments agree to the method established by the Utility in projecting off-site whole body dose rates.

P. In the event of a radiological Emergency, the Utility agrees to makce the Duke Engineering and Services Environmental Labs located in Westboro, Massachusetts, available to the State for counting samples.

Q. An accident shall be deemed to have terminated when, in the agreement of both the State and Utility, there is no longer need fbr either consideration of further protective action or surveillance related to off-site protective action. Close out of emergency classification shall be as outlined in respective Emergency Plans.

R The State of Vermont agrees to notify the State of New York (ingestion pathway zone) and coordinate off-site radiological consequences with same during any event that should occur at Vermont Yankee in the Classification of a Site or General Emergency condition.

S. The Utility-and the State agree to coordinate in the maintenance, updatin&g and exercise of both Utility and State Eme~rgency Plans, as required by Federal. regulations or as required by operational considerations.

T. This agreement may be amended by subsequent agreement betwveen the State(s) and the Utilitv.

U. Upon the effective date. this Letter of Agreement will supersede the previous Letter of Agreement signed between the State and the Utility dated January 4. 1999.

V. Upon the execution of the parties hereto. this agreement shall be effective as of the latest date iwritten below.

DIRECTOR DATE NEW HAMPSHIRE OFFICE OF EMERGENCY MANAGEMENT (NHOEM)

VEiRM2SY! ANKiEENUSCLE qP ESTA'"ON DATE Emergency Plan Revision 39 Page 122 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LETER OF AGREEMENT K.

• BETWEEN VERMONT YANKEE NUCLEAR POWER STATION AND FRANKLIN MEDICAL CENTER PURPOSE The purpose of this Letter of Agreement is to establish arrangements between Franklin Medical Center, Greenfield, MA (hereafter known as Medical Center) to accept and render treatment to radiation accident patients from the Vermont Yankee Nuclear Power Station (hereafter known as Utility).

AGREEMENT The following shall be binding upon the Medical Center and the Utility.

I. TIe person designated to coordinate emergency planning activities between the Utility and the Medical Center is the Emergency Plan Coordinator, Vermont Yankee, Brattleboro, VT for the Utility and the FMC Safety Coordinator for the Medical Center.

2. The Medical Center and Utility shall cooperate at all times in reviewing and updating

'procedures for treatment of radiation accident patients.

K' 3. The Medical Center and Utility shall join in at least one bi-annual coordinated medical drill. The Medical Center and Utility shall coordinate the scheduling of the medical drill.

4. The Utility shall offer Medical Center personnel bi-annual training on the receipt and treatment of radiation accident patients. The Medical Center and Utility shall coordinate the scheduling of the training.

5. It is the Utility's duty and obligation to notify the Medical Center in a timely manner if radiation accident patients will be transferred to the Medical Center for treatment.

6. The Utility shall provide the Medical Center with data outlined in established plant procedures when patients are to be referred to the Medical Center.

7. '.The Utility shall furnish .a person 'qualified in Health Physics radiologic'a control procedures to accompany the radiation accident patient to the Medical Center or as soon as possible after the arrival of the patient. This person shall evaluate the radiological situation, then advise and make appropriate recommendations to the senior Medical Center staff member in charge.

8. The Utility shall collect and dispose of all contaminated material and shall decontaminate Medical Center areas and supplies, as required. The Utility shall replace all supplies and/or equipment that cannot be adequately decontaminated.

Emergency Plan K> Revision 39 Page 123 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

Letter of AgreementBetweenVermontYankee and Franlin Medical Center-Page 2

9. The Medical Center shall inventory. radiological emergency equipment and supplies every six months. 'The Utility shall inventory and replace radiological emergency equipment and/or supplies after each medical drill or actual treatment df a radiation' patient.

.10. The Utility shall be responsible for initially notifying the next of kin of the incident situation. I

11. The Utility is responsible for the release of information on the incident and condition of the patient while at the plant The Medical Center is responsible for the release of information on the medical status of the patient while at the Medical Center within limits of the patient's rights to privacy. Both the Medical Center and the Utility, within their respective areas of responsibility for release of information, shall work together in a coordinated manner.

12. Medical consultation is available from resources listed in the Medical Center plan.

13. The Utility will be responsible for the cost incurred in the implementation and execution of this emergency plan: ..

a. Radiological supplies and equipment required for the execution of the plan will be provided by the Utility.

b. Training expenses such as registration fees, tuition, travel, and lodging associated with the treatment of radiation patients will be reimbursed by the Utility.

c. The Utility will replace any radiological equipment destroyed or otherwise rendered useless in the treatment of Utility patients.

d. The Medical Center will bill the Utility for services provided in actual casualty situations.

14. This Letter of Agreement may be terminated by either party with a 90 day notice.

15. This Agreement shall be effective immediately upon execution by the parties hereto.

FRANKLIN MEDICAL CENTER VERMONTYANKEE NUCLEAR POWER STATION

_7 .</A- A-,

Date Emergency Plan Revision 39 Page 124 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

AGREEMENT FOR THE OPERATION OF Ae NOAA WEATHER RADIO TRANSMTTER 13Y VERMONT Y E NUCLEA POWR STATION VERNON. VERMONT THIS AGREEMENT is entered into between the United States of America, Department of Commerce,. National Oceanic and Atmospheric Administration, National Weather Service, hereinafter referred to as "NWS", and Vermont Yankee Nuclear Power Station, hereinafter referred to as the "Cooperator".

WITNES SETH:

WHEREAS, Cooperator operates a nuclear power plant, known as Vermont Yankee, and under regulations contained in Title 10 of the Code of Federal Regulations, Section 50.47(b)(5) and Appendix E, Section 1V.D3 to Part 50, is directed to provide a system for prompt emergency notification to the public and WHEREAS, NWS operates a continuous meteorological and hydrological information and warning radio system, known as NOAA Weather Radio (NWR), which can provide a means for Cooperator to satisfy said emergency notification to the public; and WHEREAS, Cooperator and NWS desire to provide for the installation and operation of a NWR trans.mitter on Ames Hill, Marlboro, Vermont, and to provide for said emergency notification means.

NOW, THEREFORE, in consideration of the benefits of this Agreement to each party, the parties agree as follows:

1. Cooperator shall provide all information required for the radio frequency license application and operate the transmitter. strictly in accordance with the license.

2. Cost associated with the NWR transmitter will be borne by Cooperator. This includes, but is not limited to, costs for

a. purchase of equipment,

b. installation,

c. operation, including power,

d. maintenance,

c. communications links from the NWS office to the transmitter, and

f. removal or replacement of equipment Emergency Plan Revision 39 Page 125 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

3. Cooperator will provide dual transmitting equipment as specified by NWS. Cooperator is solely responsible for all aspects of equipment installation, including any necessary permits. However, connection to the NWR transmitter at Albany shall be under th1e direction of a NWS electronic technician, and in accordance with the best modem practice. The design of any device used by Cooperator or his agent to connect to the NWR transmitter must be approved byNWS before the connection is made.

4. Cooperator will use qualified and licensed radio technicians for all transmitter maintenance. Cooperator will use its best efforts in maintaining the transmitter to ensure that outages are kept to a minimum, that breakdowns and malfunctiois are quickly acted upon, and that equipment performs routinely within the Technical Specifications of said equipment and terms of the license.

5. Cooperator or designee will monitor the broadcast and will notify the Albany, New York, NWS office whenever the transmitter goes off the air and also when it again becomes operational.

6. Cooperator will perform an immediate technical checkout of the transmitter when such checkout is requested by NWS as a result of any radio frequency interference problems.

7. NWS will be allowed to check periodically the effect of Cooperator equipment on NWS equipment.

8. VNWS will maintain control over all broadcast content with the exception of messages issued in connection with an emergency at the Yankee facility.

9. All messages broadcast in connection with a Yankee emergency will be received through the Emergency Management Agencies as described in Appendix A of this Agreement, entitled, "Agreement for Activation and Use of NOAA Weather Radio in Response to an Emergency Condition at Yankee Nuclear Power Station".

10. Cooperator will hold NWS free of any liability for loss or damage to Cooperator property installed to carry out this Agreement, other than loss or damage caused by NWS's failure to use reasonable care.

11. NWS will obtain the radio frequency license for the tranitter. The License will remain the property of NWS.

12. NW/S will, if necessary, allow Cooperator to install, at Cooperator's expense, special equipment.

13. NWS personnel will exercise reasonable care to protect property of cooperator.

14. NWS will activate the notification system with the alert signal, and broadcast messages relating to a Yankee emergency when requested by authorized officials in accordance with Appendix A.

Emergency Plan Revision 39 Page 126 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

15. In the event the NWS Network System between Albany and Ames Hill is nonoperable, the NWS office will inform Emergency Management to activate the redundant'system located at WTSA Radio Station, Brattleboro, Vermont

16. NWS will provide standard programming over the transmitters (including the use of the waming signal) as required by NWS directives.

17. NWS will participate in a yearly drill to test the use of the NWS equipment as a public notification system.

18. NWS and Cooperator will coordinate and jointly issue a public announcement describing the service to be provided as a result of this Agreement. If the service is terminated for any reason, the parties will also coordinate a public statement explaining the reason(s) for termination.

19. The provision of this Agreement shall be carried out by the parties with no compensation due either party.

20. This Agreement may be amended, modified, or terminated at any time by mutual consent of the parties hereto. It may be terminated by either party upon giving at least six months' prior written notice. Although to the extent possible, recognizing the importance of this project, the parties hereto will strive to give one year's notice of intention to terminate.

IN WITNESS WHEREOF, the parties hereto have executed this Agreement effective as of the latest date written below.

CTOR, DATE NWS VEWONT .YACLEAR.POWER STATION DATE Emergency Plan Revision 39 Page 127 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

APPENDIX A AGREEMENT FOR ACTIVATION AND USE OF NOAA WEATHER RADIO -

IN RESPONSE TO AN EMERGENCY AT VERMONT YANKEE NUCLEAR POWER STATIONS THIS AGREEMENT is entered into between the Vermont Emergency Management Agency, New Hampshire Office of Emergency Management, and Massachusetts Emergency Management Agency, hereinafter referred to as Emergency Management Agencies, and the United States Department of Commerce, National Oceanic and Atmospheric Administration, National Weather Service, hereinafter referred to as the "NWS."

THIS AGREEMENT is fully a part of the 'Agreement for the Operation of a NOAA Weather Radio Transmitter by a Cooperator," hereafter referred to as the Basic Agreement, and is referenced in the Basic Agreement as Appendix A.

THIS AGREEMENT covers the responsibilities and operational considerations between Emergency Management Agencies and the NWS relative to the use of NOAA Weather Alert Radio to alert persons living in the proximity of the Vermont Yankee Nuclear Power Station in the event of an emergency condition. This Agreement fulfills, in part, the requirements set forth by NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emer encv Resonse Plans and Preparedness in Sunnort of Nuclear Power Plants: and Appendix 3 thereto.

RESPONSIBILITIES (A) THE NWS AGREES-

1) To activate warning alarm and to broadcast over the NWR transmitter, located on Ames Hill, Marlboro, Vermont, prescribed emergency public information messages pertaining to nuclear power station emergencies when so requested to do so by the Vermont Emergency Management Agency and severe weather alerts as determined by the NWS.

2) That all prescribed emergency/public information messages held in the possession of National Weather Service be given reasonable protection from misuse or accidental broadcast.

3) After being notified by the NWS, Albany, New York that the phone line to Ames Hill is nonoperational, Vermont Emergency Management will notifyr Radio Station WTSA -

Brattleboro, Vermont, to activate the NWR transmitter at Marlboro, Vermont. This procedure is necessary to avert potential damage to the NWR equipment should it be operational already and WTSA attempts to also activate the system. The State of Vermont will also be responsible for notifying WTSA what the broadcast message should be. This procedure will only be accomplished in the event of an emergency at the Vermont Yankee Nuclear Power Station requiring activation of the Public Notification System.

Emergency Plan Revision 39 Page 128 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

(B) VERMONT EMERGENCY MANAGEMENT AGENCY (VEMA) AGREES - -X

1) To provide the National Weather Service a "Standing Operating Procedure" defining the VEMA personnel by title and name authorized to request broadcast of an emergency aert message: procedures for message verification; and prescribed emergency messages approved by the Emergency Management Agencies for broadcast over National Weather Service radio.

2) To coordinate with the Directors of New Hampshire and Massachusetts Emergency Management Agencies, or their designees, before requesting the NWS to broadcast an emergency message, 'except in a fast-breakhig emergency.

3) To make requests over NAWAS, VLETS (Vermont Law . Enforcement Telecomnmunications System) and/or commercial telephone to broadcast prescribed emergency messages.

4) To notify National Weather Service upon termination of the emergency.

EUBLICITY - The mutual role of the Emergency Management Agencies and the NOAA National Weather Service will be recognized in all press releases, public presentations, or other public information/education activities carried out in regard to promoting the services provided for in the Basic Agreement.

AMENDMENTS AND TERMINATION - This Agreement may be amended at any time by -mutual consent of Emergency Management Agency(ies) and the National Weather Service. This Agreement is terminated in accordance with the provision of'and at such time as the Basic Agreernent is terminated.

IN WITNESS WHEREOF Emergency Management Agencies and the NWS have executed this Agreement effective as of the latest date written below.

Forthe V Emeney ent Agency Director Date For the United States of America.

Department of Commerce National Oceanic and Atmospheric Administration National Weather Service {C$ i  :

Date Emergency Plan Revision 39 Page 129 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

APPENDIX A J

• AGREEMENT FOR ACTIVATION AND USE OF NOAA WEATHER RADIO

• IN RESPONSE TO AN EMERGENCY AT VERMONT YANKEE NUCLEAR POWER STATIONS TIS AGREEMENT is entered into between the Vermont Emergency Management Agency, New Hampshire Office of Emergency Management, and Massachusetts Emergency Management Agency, hereinafter referred to as Emergency Management Agencies, and the United States Department of Commerce, National Oceanic and Atmospheric Administration, National Weather Service, hereinafter referred to as the `NWS."

THIS AGREEMENT is fully a part of the "Agreement for the Operation of a NOAA Weather Radio Transmitter by a Cooperator," hereafter referred to as the Basic Agreement, and is referenced in the Basic Agreement as Appendix A.

THIS AGREEMENT covers the responsibilities and operational considerations between Emergency Management Agencies and the NWS relative to the use of NOAA Weather Alert Radio to alert persons living in the proximity of the Vermont Yankee Nuclear Power Station in the event of an emergency condition. This Agreement fulfills, in part, the requirements set forth by NUREG-0654FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergencv Response Plans and Preparedness in SuDPort of Nuclear Power Plants:'and Appendix 3 thereto.'

RESPONSIBILITIES (A) THE NWS AGREES-I) To activate warning alarm and to broadcast over the NWR transmitter, located on Ames Hill, Marlboro, Vermont, prescribed emergency public information messages pertaining

• to nuclear power station emergencies when so requested to do so by the Vermont Emergency Management Agency and severe weather alerts as determined by the NWS.

2) That all prescribed emergency/public information messages held in the possession of National Weather Service be given reasonable protection from misuse or accidental broadcast.

3) After being notified by the NWS, Albany, New.York that the phone line to Ames Hill is-

- nonoperational, Vermont Emergency Management will, notify Radio Station WTSA -

Brattleboro, Verrnont, to activate the NWR transmitter at Marlboro, Vermont. This procedure is necessary to avert potential damage to the NWR equipment should it be operational already and WTSA attempts to also activate the system. The State of Vermont will also be responsible for notifying WTSA what the broadcast message should be. This procedure will only be accomplished in the event of an emergency at the Vermont Yankee Nuclear Power Station requiring activation of the Public Notification System.

Emergency Plan Revision 39 Page 130 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

(B) VERMONT EfERGErCY MANAGEMENT AGENCY (VEMA) AGREES -

1) To provide the National Weather Service a 'Standing Operating Procedure" defining the VEMA personnel by title and name authorized to request broadcast of an emergency alert message; procedures for message verffication; and prescribed emergency messages approved by the Emergency Management Agencies for broadcast over National Weather Service radio.

2) To coordinate with the Directors bf New Hampshire and Massachusetts Emergency Management Agencies, or their designees, before requesting the NWS to broadcast an emergency message, except in a fast-brealingemergency.

3) To make requests over NAWAS, VLETS (Vermont Law Enforcement Telecommunications System) and/or commercial telephone to broadcast prescribed emergency messages.

4) To notify National Weather Service upon termination of the emergency.

PUBLICffY - The mutual role of the Emergency Management Agencies and the NOAA National Weather Service will be recognized in all press releases, public presentations, or other public informnation/education activities carried out in regard to promoting the services provided for in the Basic Agreement.

AMENDMENTS AND TERMINA1TON - This Agreement may be amended at any time by mutual consent of Emergency Management Agency(ies) and the National Weather Service. This Agreement is terninated in accordance with the provision ofand at such time as the Basic Agreement is terminated  :

IN WITNESS WHEREOF Emergency Management Agencies and the NWS have executed this Agreement effective as of the latest date written below.

.Forth yetts Emergency, ana ement Agency Direffr7//E Date For the United States of America Department of Commerce National Oceanic and Atmospheric Administration National Weather Service A C Da_

Date Emergency Plan Revision 39 Page 131 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

APPENDIX A AGREEMENT FOR ACTIVATION AND USE OF NOAA WEATHER RADIO IN RESPONSE TO AN EMERGENCY AT VERMON XANKEE OR YANKEE ROWE NUCLEAR POWER STATIONS THIS AGREEMENT is entered into between the Vermont Emergency Management Agency, New Hampshire Office of Emergency Management, and Massachusetts Emergency Management Agency, hereinafter referred to as Emergency Management Agencies, and the United States Department of Commerce, National Oceanic and Atmospheric Administration, National Weather Service, hereinafter referred to as the `NWS."

TIS AGREEMENT is fully a part of the "Agreement for the Operation of a NOAA Weather Radio Transmitter by a Cooperator," hereafter referred to as the Basic Agreement, and is referenced in the Basic Agreement as Appendix A.

THIS AGREEMENT covers the responsibilities and operational considerations between Emergency Management Agencies and the NWS relative to the use of NOAA Weather Alert Radio to alert persons living in the proximity of the Yankee (Rowe) and Vermont Yankee Nuclear Power Stations in the event of an emergency condition. This Agreement fulfills, in part, the requirements set forth by NUREG-0654lEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergencv Response Plans and Preparedness in Support of Nuclear Power Plants and Appendix 3 thereto.

-RESPONST3LBII, M (A) TlHE NWS AGREES-

1) To activate warning alarm and to broadcast over the NWR transmitter, located on Ames Hill, Marlboro, Vermont, prescribed emergency public information messages pertaining to nuclear power station emergencies when so requested to do so by the Vermont Emergency Management Agency and severe weather alerts as determined by the NWS.

2) That all prescribed emergency/public information messages held in the possession of National Weather Service be given reasonable protection from misuse or accidental broadcast.

3) After being notified by the NWS, Albany, New York, tat the phone line to

'Amnes Hill is nonoperational, Vermont Emergency Management will notify Radio Station WTSA - Brattleboro, Vermont, to activate the NWR transmitter at Marlboro, Yermont. This procedure is necessary to avert potential damage to the NWR equipment should it be operational already and WTSA attempts to also activate the system. The State of Vermont will also be responsible for notifying WTSA what the broadcast message should be. This procedure will only be accomplished in the event of an emergency at Yankee (Rowe) or Vermont Yankee Nuclear Power Station requiring activation of the Public Notification System.

Emergency Plan Revision 39 Page 132 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

(D) VERMONT EMERGENCY MANAGEMENT AGENCY (VEMA) AGREES -

1) To provide the National Weather Service a "Standing Operating Procedure" defining the VEMA personnel by title and name authorized to request broadcast of an emergency alert message; procedures for message verification; and prescribed emergency messages approved by the Emergency Management Agencies for broadcast over National Weather Service radio.

2) To coordinate with the Directors of New Hampshire and Massachusetts Emergency Management Agencies, or their designees, before requesting the NWS to broadcast an emergency message, except in a fast-brealdng emergency.

3) To make requests over NAWAS, VLETS (Vermont Law Enforcement Telecommunications System) and/or commercial telephone to broadcast prescribed emergency messages.

4) To notify National Weather Service upon termination of the emergency.

PUBLIC - The mutual role of the Emergency Management Agencies and the NOAA National Weather Service will be recognized in all press releases, public presentations, or other public informationleducation activities carried out in regard to promoting the services provided for in the Basic Agreement.

AMENDMENTS AIND TERMINATION - Wlis Agreement may be amended at any time by mutual consent of Ernergency Managetfent Agency(ies) and the National Weather Service. This Agreement is terminated in accordance with the provision of and at such time as the Basic Agreement is terminated.

IN WITNESS WHEREOF Emergency Management Agencies and the NWS have executed -tis Agreement effective as of the latest date written below.

For the New Hampshire Office of Emergency Management Director -A Date For the United States of America Department ofCommerce National Oceanic and Atmospheric Administration ational Weather Service Ad ^ .

Date Emergency Plan Revision 39 Page 133 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LEITER OF AGREEMENT BETWEEN VERMONT YANKEE NUCLEAR POWER STATION AND BRATTLEBORO MEMORIAL HOSPITAL.

The purpose of this Letter of Agreement is to establish arrangements with Brattleboro Memorial Hospital to accept and render treatment to radiation accident patients from the Vermont Yankee Nuclear Power Station.

II. The following shall be binding upon the Hospital and the Utility:

1. The Hospital and Utility shall cooperate at all times in reviewing and updating procedures for treatment of radiation accident patients.

2. The Hospital and Utility shall join in at least one annual coordinated medical drill. The Hospital and Utility shall coordinate the scheduling of the medical drill team.

3. Selected Hospital personnel shall participate in an ongoing training program to meet the needs of the Hospital personnel. Hospital and Utility shall coordinate the scheduling of the training sessions.

4. It is the Utility's duty and obligation to notify the Hospital (Emergency Room) in a timely manner if radiation accident patients will be transferred to the hospital for treatment.

5. The Utility shall provide the Hospital with the data outline in established procedures wvhen patients are to be referred to the hospital.

6. The Utility shall furnish a person qualified in Health Physics radiological control procedures to accompany or meet the radiation accident patient at the Hospital. This person shall evaluate the radiological situation, then advise and make appropriate recommendations to the senior hospital staffmember in charge.

7. The Utility shall collect and dispose of all contaminated material and'shall decontaminate hospital areas and supplies, as required. The Utility shall replace all supplies and/or equipment that cannot be adequately decontaminated.

8. Ile Utility shall inventory emergency equipment and supplies every six months. In addition, the Utility shall inventory and replace emergency equipmentland or supplies after each medical drill or actual treatment of a radiation patient.

9. The Utility shall be responsible for initially notifying the next of kin of the accident situation.

Emergency Plan Revision 39 Page 134 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

10. The Utility is responsible for the release of inforniation on the incident and condition of patient while at the plant. The Hospital is responsible for the release of infoirmation on the medical status of the patient while at the hospital within the limits of the patient's rights to privacy. Both the Hospital and the Utility, within their respective areas of responsibility for release of information, shall work together in a coordinated manner.

11. This Letter of Agreement supersedes all previous agreements between Brattleboro Memorial Hospital and Vermont YankeeNuclear Power Station.

12. This Agreement shall be effective immediately upon execution by the parties hereto.

ont Yanak Power Station Brattleboro Memorial Hospital

.3 ate .at AM -o J ate Datd Emergency Plan Revision 39 Page 135 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LETTER OF AGREEMENT BETWEEN VERMONT YANLEE NUCLEAR POWER STATION AND

-RESCUE,INC. AMBULANCE SERVICE I.PUR.POSE The purpose of this Letter of Agreement is to establish arrangements with Rescue, Inc.

Ambulance Service, Brattleboro, Vermont to provide off-site medical transportation support to Vermont Yankee.

II. AGREEMENT The Rescue, Inc. Ambulance Service and Vermont Yankee agree to the following:

A. Rescue, Inc. will respond to all contingencies involving personal injury at Vermont Yankee Nuclear Power Station, when requested.

B. Attend off-site medical support training given at Brattleboro Memorial Hospital on an annual basis, C. Participate imn a minimum of one emergency medical drill per year involving simulated patients from Vermont Yahkee. Details of each drill will be mutually agreed upon.

D. Vermont Yankee will notify Rescue, Inc. of the scheduled training sessions to be held at Brattleboro Memorial Hospital.

E. Vermont Yankee will provide the facilities and trained personnel to assist in the decontamination of all equipment used by Rescue, Inc. when responding to emergencies and/or drills involving radioactive material.

F. Vermont Yankee agrees to send a Health Physicist with the patient to the hospital, if available.

G. Upon the effective date, this Letter of Agreement will supersede all previous agreements signed between. Rescue, Inc. and the plant..

H. Upon the execution of the parties hereto, this Agreement shall be effective.

EXECUTIVE DIRECTOR VWAONTYANO RESCUE, INC. NUCLEARPOWER STATION o 3- 1 - Ltarl __ __ __ __ __ _

Date Date Emergency Plan Revision 39 Page 136 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LETTER OF AGREEMENT BETWEEN VERMONT YANKEE NUCLEAR PONWER STATION AND.

TBE VERNON, VT, FIRE DEPARTMENT The purpose of this Letter of Agreement is to establish arrangements with the Vernon Fire Department to provide firefighting support to the Vermont Yankee Nuclear Power Station when required, and to establish authorities for firefighting on Vermont Yankee property.

The Vernon Fire Department agrees to provide firefighting mnapower and equipment support to the Vermont Yankee Nuclear Power Station when requested. Vermont Yankee staff will provide escort for the fire department when entering the plant site. The Vernon Fire Department further agrees to test the siren located at Vermont Yankee on the first Saturday of every month.

Authorities for firefighting on Vermont Yankee property are established as follows:

1. Vermont Yankee remains primary command authority in the following areas:

a. All buildings, structures and areas within, and including, the inner Protected Area boundary fence;

b. Security Gate House #2 and 3:

c. The low-level waste storage area outside the North Protected Area boundary fence;

d. The intake and Discharge Structures;

e. The Cooling Towers;

f. The Relay House; and,

g. The 115 KV and 345 KV Switchyards.

2. The Vernon Fire Department is delegated primary command in all other areas on Station property not listed above. The Vernon.Fire Departnent agrees to obtain Station Control Room approval before commencing firefighting operations. For any fire in these areas, Vermont Yankee will assign a minimum of one plant Fire Brigade member to:

a. advise the Vernon Fire Department regarding conditions and circumstances relevant to the fire such as: plant operational concerns; structure lay-out; combustible material loading: and potential electrical, chemical, radiological or other hazards; and,

b. act as liaison between the Vernon Fire Department and the Station Control Room in the interests of plant operational and firefighter safety.

'This letter of Agreement shall be effective immediately upon execution by the parties representing the subject organizations. This Agreement will remain in effect until superceded by another Letter of Agreement or by notification of withdrawal of either party to the remaining party.

Ve&oYankee Nuo Power Station Fnt Date Date Emergency Plan Revision 39 Page 137 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LETTER OF AGREEMENT BETWEEN VERMONT YANKEE NUCLEAR POWTR STATION AND BRATTLEBORO FIRE DEPARTMENT PURPOSE The purpose of this Letter of Agreement is to establish arrangements with the Brattleboro (VT)

Fire Department to provide for the recharging of Scott Air-Pac type breathing air bottles in support of Vermont Yankee.

II. AGREEMENT The Brattleboro Fire Department and Vermont Yankee agree to the following:

A. Vermont Yankee wvill monitor and deliver to the Central Fire Station on Elliott Street in Brattleboro, spent breating air bottles for refill..

B3. The Brattleboro Fire Department will refill the spent bottles, or will advise Vermont Yankee when the filled bottles will be available.

C.; Vermont Yankee will pay an established nominal fee to the Brattleboro Fire Department for services rendered when the filed bottles are picked up.

D. Under emergency conditions at Vermont Yankee, the Brattleboro Fire Department will provide priority refill service to Vermont Yankee, if possible; however, it is understood that the priority status will be detennined by the conditions existing at the time the service is requested by Vermont Yankee.

E. Upon the execution of the parties hereto, this Agreement shall be effective.

'VmlntYakeuclea6ve'rStation . BrattlebroArepvtent/

4lAz il It o 0 0 0 '

Date Date Emergency Plan Revision 39 Page 138 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

S. VERMONT YANKEE NUCLEAR POWER STATION PO Box 7002, 185 Old Ferry Road, Brattleboro, VT.05302.7002 f (802) 257.5271 Letter of Agreement This letter serves as an agreement between Vermont Yankee Nuclear Power Station and Duke Engineering and Services (DE&S) for the use of the DE&S offices as an alternate News Media Center.

Provisions of this agreement are described in the following Emergency Preparedness documents:

o DE&S Emergency Support Plan, Section 4.0, "Emergency Facilities" o DE&S Emergency Support Plan, Implementing Procedure No. 14, "Vermont Yankee Alternate News Media Center" a Vermont Yankee Emergency Plan! Section 6.5.1, "News Media Center" In the event the primary Vermont Yankee News Media Center must be relocated due to emergency conditions, Duke Engineering and Services will be contacted for use of the DE&S facility.

The Vermont Yankee Nuclear Power Station will pay for all expenses for the use of the DE&S facility during a Vermont Yankee emergency or for an authorized facility exercise.

- e -. /zllelol .

Michael A. Balduzzi Date Pet6 Guiehino Date Sr. Vice President & ChiefNuclear Officer 'Vice President -Northeastern Region Vermont Yankee Nuclear Power Station Duke Engineering and Services Emergency Plan Revision 39 Page 139 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

INSPO¶7 Institute of NuclearPower Operations Suce 100 700 Galleda Parkwa, SE Atlanta, GA 30339-5957 770-6448000 FAX 77o-6s549.

September 24, 2003 (revised 2/26104)

Dear Ladies and Gentlemen:

This letter certifies that the plant emergency assistance agreement between INPO and its member utilities remains in effect. In the event of an emergency at your utility, INPO will assist you in acquiring the help of other organizations in the industry, as described in Section I of the Emergency Resources Manual, INPO 03-001. If requested, INPO will provide the following I assistance:

• Facilitate technical information flow from the affected utility to the nuclear industry.

• Locate replacement equipment and personnel with technical expertise.

• Obtain technical information and industry experience regarding plant component and systems.

• Provide an INPO liaison to facilitate interface.

This agreement will remain in effect until terminated in writing. Should you have questions, please call me at (770) 644-8304 or e-mail mossdjeinpo.org.

Sincerely,

• David J. Moss Manager Radiological Protection DJM/jls L03-5Q01S Emergency Plan Revision 39 Page 140 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

VERNON, VERMONT BOARD OF SELECTMEN Chairman James Polhemus Leonard Peduzzi Patricia O'Donnell Dean Shover Conrad Waite i

t March 13, 2000 Vermont Yankee Nuclear Power Station II 185 Old Ferry Road Brattleboro, Vr 05301

Dear Sirs:

This letter supersedes previous letters from the Town of Vernon, Vermont dated April 29, 1985; July 30, 1989; and December 17, 1998. This letter will grant you permission to use our facilities at the Town Office Building as a personnel assemble area In the'remote possibility of an accident at Vermont Yankee, It is our understanding that you will not require any storage space in the building.

However, If there were a need for you to utilize our facilry, you would bring equipment as required with you.

i f

If you require any further information please contact me.

III Sincerely, James L Po emus Chairman Vernon Board of Selectmen I

Chartered 1753 667 Governor Hunt Rd. - Vernon, Vermont 05354-9484

• TeL (802) 257-0292 . FAX: (802) 2544561 Emergency Plan Revision 39 Page 141 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LETTERS OF AGREEMENT BETWEEN VERMONT YANKEE NUCLEAR POWER STATION AND

. YANKEE NUCLEAR POWER STATION This Letter of Agreement is to establish a mutual assistance for sample analysis and to arrange for the use of decontamination facilities in the event of an accident at the Yankee Nuclear Power Station or the Vermont Yankee Nuclear Power Station.

Both Nuclear Power Stations agree to the following:

I. In the event laboratory facilities at one of the aforementioned plants are inoperable, the unaffected plant will make its laboratory facilities available for radiological and chemical analyses of air, water, filter, or other samples obtained from the affected plant.

2. In the event on-site decontamination facilities at one of the aforementioned plants are disabled, the unaffected plant will make its decontamination facilities available for the affected plant.

3. YankeeNuclear Power Station is undergoing decommissioning. YankeeNuclear Power Station will offer the above services to the extent they exist on-site.

Upon execution ofthe parties hereto, this agreement shall be effective.

VQ resident Sr. Vice President k ChiefNuclear Officer Yankee Atomic Electric Co. Vermont Yankee Nuclear Power Station

. -: 1 IDt - *)

I (Date) (Date)

Emergency Plan Revision 39 Page 142 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

Department of Energy Brookhaven ANea Office Fi f~ P.O. Box 5000 Upton, NewYork 11973 JUN 3 200Z TO: DISTRBUTIONLIST

SUBJECT:

DEPARTMENT OF ENERGYS (DOE) RADIOLOGICAL ASSISTANCE PROGRAM (RAP) MEMORANDUM OF UNDERSTANDING The DOE BWookhaven Area Office (BAO) as the Regional Coordinating Office (RCO) for DOE's Region 1, after discussion with representatives from the U.S. Nuclear Regulatory Comnmission (USNRC) and the Federal Emergency Management Agency (FEMA), has concluded that individual memorandums of understanding (MOUs) are no longer required.

Numerous federal laws, regulations, and DOE Orders, that are currently in existence, require DOE to maintain an ever-ready response capability for coping with any nuclear/radiological incident in support of FEMA and the NRC. The elimination of the annual letters would in no.

way impact the assistance or support that BAO is required to provide and has maintained over

'the years. BAO, as the RCO for DOE Region 1, will carry out that assistance required by law, regulation, and DOE Orders.

If you have any questions or would like further details, please contact me at (631) 344-7309.

Sincerely,

<<teven M. Centore Regional Response Coordinator PC Doc #4235115530.1 A com~powan of the DOE ChkWg OpaadonioMeic Emergency Plan Revision 39 Page 143 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

Department of Energy

• Oak Ridge Operations Office' P.O. Box 2001 .

!* '~Oak Ridge, Tennessee 37831-Edxby 24, 203 Mr. Alain Grosjean Emergency Programs Entergy Nuclear Northeast EntergyNuclear Operations, Inc.

440 Hamilton Avenue Wbite Plains, NewYork 10601-1813

Dear Mr. Grosjean:

LETTER OF AGREEMENT- RADIATION EMERGENCY ASSISTANCE CENTERRINI G. SITE (REAC/TS) SUPPORT Please reference your letter of February 4, 2003, requesting that the Department of Energy (DOE) REACITS facilities and team be available to provide back-up capability and assistance to the Entergy Nuclear Northeast's nuclear facilities in the event of a radiological emergency. This response constitutes our agreement to provide this service upon your request.

We wish to remind you that our REAC/TS facilities in the Oak Ridge Institute for Science and Education (ORISE) are government controlled and operated by the Oak Ridge Associated Universities (ORAU) under contract with DOE. Therefore, REACITS is prohibited from competing with commercial firms, which can provide radiological emergency services. Only if the magnitude or uniqueness of a radiological emergency exceeds your in-house and comnnercially available capabilities would REAC/TS be authorized to provide back-up services.

Since these facilities are government controlled, no fee or retainer is required to assure the availability of back-up services by REACITS. However, if you utilize the services of REACITS, we should expect to recover those costs, which could reasonably be related to handling such an incident, including all charges billed to DOE or ORISE by hospitals and physicians. Information concerning the REACTS facilities, staff, services available, and procedures for seeking REACIS assistance can be obtained by direct contact with the REAC/TS Director, Dr. Robert C. Ricks, ORISE, Post Office Box 17, Oak Ridge, Tennessee 37831, or (865) 576-3131.

Sincerely, Gregory A. Mills Contracting Officer's Representative (Alternate)

Emergency Plan Revision 39 Page 144 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

Mr. Alain Grosjean Edbruy 24,

-. cc:

R M. Kennard, MS-48, ORISE Rub C. Ricks, MS-39, ORISE Emergency Plan Revision 39 Page 145 of 166 Entergy Vermont Yankee

APPENDIX E (Continued)

LElTER OF AGREEMENT BETWEEN ENTERGY NUCLEAR VERMONT YANKEE AND VERMONT YANKEE NUCLEAR POWER CORPORATION i

This Letter of Agreement is to establish a mutual understanding of notification in the event of an accident at the Entergy Nuclear Vermont Yankee Plant.

During working hours, ENVY will notify the VYNPC office, located on the second floor of the Training Building in Brattleboro, VT, of the declared event in two ways:

I. Public Address system announcement of the event, and i 2. ENVY Emhployee Services & Facilities personnel to verbally communicate II event.

2 VYNPC personnel will be required to evacuate the building at the time of notification.

During off-hours the Emergency Plan Manager, or designated alternate, will notify VYNPC personnel via phone of the event.

I Upon termination of the event, VYNPC will be notified by the Emergency Plan Manager, or designated alternate, of the event termination.

Upon execution of the parties hereto, this agreement shall be effective.

Vice President o erations Vermont Yankee Nuclear Power Corp. Entergy Nuclear Vermont Yankee

/I /9 Ic-z (Date) (Date)

Emergency Plan Revision 39 Page 146 of 166 Entergy Vermont Yankee

APPENDIX F EVACUATION TIME ESTIMATES This Appendix contains a summary of the updated Evacuation Time Estimates Within the Plume Exposure Pathway Emergency Planning Zone for the Vermont Yankee Nuclear Power Station.

Emergency Plan Revision 39 Page 147 of 166 Entergy Vermont Yankee

APPENDIX F (Continued)

VERMONT YANKEE EVACUATION TIME ESTIMATE (ETE) STUDY

SUMMARY

The following is a summary of the evacuation time estimates for those portions of Vermont, New Hampshire and Massachusetts within the Plume Exposure Pathway Emergency Planning Zone (EPZ) for the Vermont Yankee Nuclear Power Station.

The evacuation time estimate study has been developed to support the radiological emergency response plans of the States, local communities and Vermont Yankee. The study has been prepared in accordance with NUREG-0654/FEMA-REP-1, Rev. 1, Appendix 4, Evacuation Time Estimates within the Plume Exposure Pathway Emergency Planning Zone, which is the current regulatory guidance for preparing evacuation time estimates.

The primary purpose of the evacuation time estimate study is to assess the relative times necessary for the evacuation of the Vermont Yankee EPZ. To accomplish this, the study, which identified the approximate time frame associated with a number of evacuation scenarios for a range of seasonal, daily and weather conditions, gives detailed consideration of the roadway network and population distribution. These are representative time frames for the evacuation of various areas around VY once a decision has been made to evacuate.

The evacuation time estimates have been developed using the Interactive Dynamic Network Evacuation (IDYNEV) traffic simulation computer model. Detailed site-specific evacuation roadway network and vehicle data, together with public mobilization times were used as inputs to determine the evacuation time estimates.. Evacuation time estimates for the general population within the Vermont Yankee EPZ were developed for various combinations of the K> seventeen EPZ towns for partial or full EPZ scenarios.

Based on information in Vermont Yankee's Emergency Plan Implementing Procedure OP 351 1, "Offsite Protective Action Recommendations", the seventeen EPZ towns were combined into 25 primary evacuation zones. These include 8 primary evacuation zones encompassing the towns in the 0-5 mile downwind sectors around the plant and 16 primary evacuation zones encompassing the towns within an approximate 0-5 mile radius and specific downwind sectors 5-10 miles around the plant. In addition, one primary evacuation zone encompassing towns falling within a 0-2 mile radius of the Vermont Yankee Nuclear Power Station was also identified.

Evacuation scenarios were developed by combining a primary evacuation zone with a specific season, time of day, and weather condition to simulate evacuation conditions. Evacuation time estimates were developed for the 25 primary evacuation zones and the entire EPZ for two seasons (summer and winter), two time periods (day and night), and two weather conditions (normal and adverse). A total of 208 evacuation scenarios were considered in the evacuation time estimate study.

Emergency Plan Revision 39 Page 148 of 166 Entergy Vermont Yankee

APPENDIX F (Continued)

Assumptions Assumptions regarding population, public notification, mobilization times, vehicle ownership, road network conditions, emergency plan and procedure implementation, and other factors involved in an evacuation are necessary in determining ,the results of evacuation simulation modeling. Consistent with' the guidance in NUREG-0654,' the following are some of the key assumptions used in the evacuation time estimate study.

1. Population Groups and Evacuation Scenarios a) The general population, which basically comprises permanent, transient, and special facility populations, varies for a winter day and night, and a summer day and night.

b) Based on the 1990 United States Census, a total of 34, 405 permanent residents within the Vermont Yankee EPZ have been identified. This includes 16, 352 Vermont residents; 10,474 New Hampshire residents; and 7,579 Massachusetts residents.

c) The estimated summer daytime population of 45,322 persons includes the permanent resident, seasonal resident, employee, applicable transient, and special facility populations.

d) The'estimated summer nighttime population of 43,923 persons 'includes the permanent resident, seasonal resident, nighttime employee, overnight transient, and applicable special facility populations.

e) The estimated winter daytime population of 48,320 persons includes the permanent resident, daytime employee, applicable transient, and special facility populations.

f) The estimated winter nighttime population of 39, 886 persons includes the permanent resident, nighttime employee, applicable transient, and special facility populations.

g) Evacuation scenarios include winter day and night and summer day and night,

'under normal and adverse weather conditions.

h) Special events are activities of relatively short duration which may attract significant numbers of transients to the EPZ, or conditions such as closure of roadways along primary evacuation routes. Based on a review of potential special events, a peak population special event scenario occurring during fall foliage season was considered.

Emergency Plan Revision 39 Page 149 of 166 Entergy Vermont Yankee

APPENDIX F (Continued)

2. Mobilization Times General population mobilization times have been developed in accordance with NUREG-0654. Mobilization includes three key events: notification, time to return home, and preparing for evacuation.

a) Notification is the time for the public to receive a warning with a recommendation to evacuate. The alert and notification system consists of sirens, tone alert radios, and route alerting. In accordance with Vermont Yankee's alert and notification system, the time to notify the EPZ population is 15 minutes, except for special alerting locations which may require up to 45 minutes for alerting.

b) The permanent population preparation is the time required for residents to make preparations for leaving home. It is assumed that the permanent population could prepare for an evacuation within 60 minutes during the day or night.

c) The time required for employees and/or residents to return home from work or other activities in the EPZ during the day under normal weather conditions is assumed to be 15 minutes. Under adverse weather conditions, the average time is assumed to be 25 minutes due to reduced roadway travel speed and capacity.

d) Special facility preparation times (e.g., schools, day care. Elderly centers, hospitals) are determined on a facility-specific basis. Based on survey results,:.

nearly all identified special facilities can be prepared to evacuate-in less than 60 minutes.'

e) Based on a survey of transient facilities, most facility evacuations will begin shortly after notification. In accordance with the Vermont Yankee alert and notification system, notification times range from several minutes to 45 minutes for the more remote locations. It is assumed that visitors to transient facilities would be mobilized to evacuate within 45 minutes.

f) Total mobilization times are determined by summing the appropriate event times.

A normal distribution, derived from the sum of the appropriate average event times, is used to determine the loading rate of population/vehicles onto the evacuation road networks.

g) Vehicle loading for special and transient facility populations is derived from the special/transient facility preparation times discussed above.

Emergency Plan Revision 39 Page 150 of 166 Entergy Vermont Yankee

APPENDIX F (Continued)

3. Public ResDonse Behavior a) Persons within the EPZ, when instructed to evacuate, will leave.

b) People in the outer primary evacuation zones will not evacuate when an inner primary evacuation zone is the only zone recommended to be evacuated.

c) People without vehicles will receive rides from either'neighbors or designated public service vehicles in accordance with local RERPs.

4. Vehicle Ownership/Use Factors a) Private.vehicles will be the primary mode of evacuation for the permanent and seasonal resident population.

b) In accordance with NUREG-0654 and supported by vehicle ownership data, one vehicle per household is assumed for this study.

c) Adequate transportation (either private or emergency vehicles) will be provided for special facility -and transportation dependent populations.

d) Adequate private transportation will be available for recreation areas.

e) One vehicle per campsite, one vehicle per hotel room, or more specific vehicle occupancy factors developed from a survey of recreational areas in the EPZ, is assumed for this study.

5. Operation of Evacuation Road Network a) Evacuation will occur on those routes identified in the EPZ town RERPs (see Figure F-I).

b) All primary evacuation routes are open to traffic and will be passable. During the winter, EPZ towns will have implemented snow removal activities.

c) Traffic flow on evacuation routes is primarily in a uniform direction away from the site and with little'cross traffic.-

d) Traffic rules and controls will be obeyed, and only the proper travel lanes will be used (not shoulders or opposing flow lanes). Traffic lights will be functioning normally or emergency traffic control measures will be in place.

e) Evacuation routes are free of major traffic at the start of the evacuation (except in a special event analysis for fall when traffic is assumed on the major EPZ thoroughfares).

Emergency Plan Revision 39

• E Page 151 of 166 1 Entergy Vermont Yankee

APPENDIX F (Continued) f) Adverse weather conditions are those that may impair visibility and/or traction, such as light snow, icing, rain, or fog. Roadway capacities will be reduced to 80% of normal weather speed and capacity during adverse weather during the summer and 75% of normal weather speed and capacity during the winter.

6. Radiological Emergency Response Plan (RERP) Consistencv a) Evacuation will occur according to established State and local RERPs and procedures.

b) Adjacent inner evacuation zones will be evacuated simultaneously with the outer evacuation zones as recommended in OP 3511.

c) The portion of the general population that resides in and is near the EPZ when notified to evacuate will return home to assemble the family unit.

d) Special facilities (e.g., schools, hospitals, day care centers, nursing homes) may be mobilized for possible evacuation at the Alert or Site Area emergency classification level; however, for the purposes of this analysis, evacuation of special facilities will occur simultaneously with the general population.

e) Schools (including affiliated day care facilities) will evacuate as units. Students will not be sent home;  :

f) Children at day care facilities not affiliated with schools will be picked up by parents or accompanied to reception centers in buses.

g) Appropriate traffic and access control points will be manned.

h) Sufficient resources are available to transport transportation-dependent individuals or special facility populations.

Results The results of the computer analysis indicate that for the general population, the evacuation time estimates (in which traffic associated with Brattleboro was found to be the limiting factor) for normal weather conditions'in summer and winter, range from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 20 minutes during the day to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 55 minutes at night.' For adversedweather conditions, the time estimates range from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> during the day to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 15 minutes at night.

The evacuation time estimates for those primary evacuation zones excluding Brattleboro, range from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during the day to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 50 minutes at night, under normal weather conditions. During adverse weather conditions, the times range for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 20 minutes during the day to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 55 minutes at night.

Emergency Plan Revision 39 Page 152 of 166 Entergy Vermont Yankee

APPENDIX F (Continued)

For those evacuation scenarios including Brattleboro, significant vehicle congestion resulting in J) travel delay was predicted by the IDYNEV model. Evacuation times for the primary evacuation zones including Brattleboro, ranges from 20 minutes to 40 minutes longer that those excluding Brattleboro.

The scenarios exhibiting the largest time differences were predicted to occur during the winter day, when a significant number of vehicles were assumed to be present due to public schools being in session. This lends conservatism to the analysis, since it is likely that most schools would be evacuated prior to the general population.

Results indicate that in nearly all instances, special facilities can be evacuated within the same time frame as the general population. To add conservatism to the analysis, special facilities were considered to evacuate along with instead of prior to the general population.

In the special event scenario analysis (where the base population of Brattleboro was increased by 5,500 to approximately 17,750), the evacuation time estimate for the full EPZ winter day normal weather scenario increased to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 45 minutes. This represents a 25 minute increase over the winter day normal weather evacuation scenarios which include Brattleboro.

K)S Emergency Plan Revision 39 Page 153 of 166 Entergy Vermont Yankee

C C. C APPENDIX F (Continued) 11 Yigure F-I Vermont Yankee Nuclear Power Station Evacuation Road Network Emergency Plan Revision 39 Page 154 of 166 Entergy Vermont Yankee

APPENDIX G INDEX OF EMERGENCY PLAN IMPLEMENTING PROCEDURES AND SUPPORT PLANS Emergency Plan Revision 39 Page 155 of 166 Entergy Vermont Yankee

APPENDIX G (Continued)

1. EMERGENCY PLAN IMPLEMENTING PROCEDURES AP 3125 Emergency Plan Classification and Action Level Scheme OP 3504 Emergency Communications

'OP 3505 Emergency Preparedness Exercises and Drills OP 3506 Emergency Equipment Readiness Check OP 3507 Emergency Radiation Exposure Control OP 3508 Onsite Medical Emergency Procedure OP 3509 Environmental Sample Collection during an Emergency OP 3510 Offsite and Site Boundary Monitoring OP 3511 Offsite Protective Action Recommendations OP 3513 Evaluation of Offsite Radiological Conditions

'OP 3524 Emergency Actions to Ensure Initial Accountability and.Security Response OP 3525 Radiological Coordination OP 3531 Emergency Call-in Method AP 3532 Emergency Preparedness Organization OP 3533 Post Accident Sampling of Reactor Coolant OP 3534 Post Accident Sampling of Plant Stack Gaseous Releases OP 3535 Post Accident Sampling and Analysis of Primary Containment OP 3536 In-plant Air Sample Analysis with Abnormal Conditions OP 3540 Control Room Actions During an Emergency OP 3541 Activation of the Technical Support Center OP 3542 Operation of the Technical Support Center OP 3543 Activation of the Operations Support Center Emergency Plan Revision 39 Page 156 of 166 Entergy Vermont Yankee

APPENDIX G (Continued)

1. EMERGENCY PLAN iMPLEMENTING PROCEDURES (Continued)

OP 3544 Operation of the Operations Support Center OP 3545 Activation of the Emergency Operations Facility/Recovery Center OP 3546 Operation of the Emergency Operations Facility/Recovery Center OP 3547 Security Actions During an Emergency OP 3712 Emergency Plan Training

11. SUPPORT PLANS*

The Vermont Yankee Severe Accident Management Program (PP 7019)

The Vermont Yankee Joint News Center Implementing Guidelines The Vermont Yankee Security Plan The Vermont Yankee Fire Protection and Appendix R Program (PP 7011)

Corporate Support During Emergencies (ENN-EP-601)

The State of Vermont Radiological Emergency Response Plan The State of New Hampshire Radiological Emergency Response Plan The Commonwealth of Massachusetts Radiological Emergency Response Plan for Fixed-Site Nuclear Facilities The Federal Radiological Emergency Response Plan (FRERP)

Procedure for Admission and Management of Radioactively Contaminated Patients at Brattleboro Memorial Hospital

• - This list does not reference any of the emergency plan arrangements specified in Appendices D and E of this plan.

Emergency Plan Revision 39 Page 157 of 166 Entergy Vermont Yankee

APPENDIX H PUBLIC NOTIFICATION SYSTEM Emergency Plan Revision 39 Page 158 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Vermont Yankee has completed the installation of the equipment necessary to meet the requirements outlined in NUREG-0654 for alerting the public within the Vermont Yankee EPZ.

The equipment consists of 11 T-Bolt sirens, 6 STH-10 sirens, 2 3T22 sirens, 1 Model #5 siren, and approximately 5000 NWS Tone-Alert receivers. The attached town maps indicate the location of each siren by type.

When an emergency condition exists which requires the Public Notification System to be activated, the emergency Management Agencies of Massachusetts, New Hampshire, and Vermont coordinate the activation of the Public Notification System (sirens, mobile PA systems, weather alert receivers, emergency broadcasting stations, etc.). After the coordination, the respective states notify local response organizations to activate the system to alert the affected population. Coordination of the three states is very important prior to activation due to the overlap of the radio stations and sound devices outside a state into the other affected states. The responsibility for activating the prompt Public Notification System rests with the State and Local Governments.

In the event of an emergency situation, which requires rapid implementation of alerting the public, the respective state agencies (State Police and/or Emergency Management) immediately notify the Emergency Broadcasts Stations to provide advisory information to the public. Simultaneously, the states include the activation of the Public Notification System in their initial message to the local response organizations. Coordination is not conducted during a fast breaking event.

Emergency response organizations have a 24-hour capability of alerting and providing instructions to the public; Each state has made provisions for issuing emergency instructions to the public.

Descriptions of the information to be immediately issued and updates of the information are outlined in the respective State Emergency Response Plans.

ATTACHMENTS:

I. Town Map - Brattleboro, VT

2. Town Map - Colrain, MA

3. Town Map - Hinsdale, NH

4. Town Map - Northfield, MA

5. Town Map - Winchester, NH

6. Town Map- Vernon, VT Emergency Plan Revision 39 Page 159 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment I Town Map - Brattleboro, VT 16OOM 80 Oft KEY:

1 - Thunderbolt (located on Putney Road) 2 - STH-10 (located at the Brattleboro Municipal Building) 3 - Thunderbolt (located at the Town Highway Garage on Fairground Road)

Emergency Plan Revision 39 Page 160 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment 1 (Continued)

Town Map - Brattleboro, VT KEY:

4 - Thunderbolt [located on private property (Roland LaRose) 100 ft. off Rte. 9 West]

5 - STH-1 0 (located in West Brattleboro at the West Brattleboro Fire Station) 6 - STH-10 (located in West Brattleboro behind the Vermont State Police Barracks)

Emergency Plan Revision 39 Page 161 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment 2 Town Map - Colrain, MA

. . ONGORERRIOO I Everett H1i I Tagqard I HillI Chandler Hill N Aunt

ophies Peak

. a Hope, Mount ver Colrain

,at Mountain a

¢/

rl KEY:

1 - Thunderbolt Siren (located off Rte. 112 across the street from Truss Building Shop) 2 - Model #5 Siren (located along Rte. 112 in the community known as Griswoldville)

Emergency Plan Revision 39 Page 162 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment 3 Town Map - Hinsdale, NH KEY:

1 - Thunderbolt (located on Meeting House Rd at the Town Well Site) 2 - STH-1 0 (located at the Hinsdale Fire Station)

Emergency Plan Revision 39 Page 163 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment 4 Town Map - Northfield, MA KEY:

1 - Thunderbolt (located along Rts 10 and 63 across from the Northfield Campus, Mt.

Herman/Northfield School) 2 - STH-10 (located at the Fire Station along Rts 10 and 63) 3 - Thunderbolt (located at the South end of town at the Jct of Rte 63 and Luckey Clapp Rd)

Emergency Plan Revision 39 Page 164 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment 5 Town Map - Winchester, NH KEY:

1 - Thunderbolt (located off Rte 119 in the community of Ashuelot on Mr. Amarosa's property -

Fiddle Hill) 2 - 3T-22 (located at the Fire Station) 3 - Thunderbolt (located on Town each Road off of Rte 10 on Forest Lake - Town Well) 4 - STH-1 0 (located on Rte 10 just over the town line into the town of Swanzey)

Emergency Plan Revision 39 Page 165 of 166 Entergy Vermont Yankee

APPENDIX H (Continued)

Attachment 6 Town Map - Vernon, VT K>

KEY:

1 - Thunderbolt (located at the Nuclear Power Plant north of the stack) 2 - Thunderbolt (located at the Fire Station on Rte 142) 3 - 3T-22 (located at the recreational area on Lily Pond Road)

Emergency Plan Revision 39 Page 166 of 166 Entergy Vermont Yankee