BVY 13-104, Emergency Plan Change, Revision 53

Emergency Plan Change, Revision 53

ML14339A646
Person / Time
Site:	Vermont Yankee
Issue date:	12/19/2013
From:	Mckenney M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 13-104, FOIA/PA-2015-0012
Download: ML14339A646 (180)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 185 Old Ferry Road Entergy Brattleboro, VT 05302-0500 Tel 802 258 4183 Michael P. McKenney Emergency Planning Manager BVY 13-104 December 19, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Emergency Plan Change, Revision 53 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

Dear Sir or Madam:

In accordance with 10 CFR 50.54(q) Entergy Nuclear Operations, Inc. is providing Revision 54 of the Vermont Yankee Nuclear Power Station Emergency Plan including the description of changes and the 10 CFR 50.54(q) Screening and Evaluation Forms.

Changes made in this revision were determined to not need prior NRC review and approval.

There are no new regulatory commitments contained in this submittal.

Should you have any questions concerning this submittal, please contact me at 802-258-4183.

Sincerely, MPM/jha

BVY 13-104/Page 2 of 2

Attachment:

Emergency Plan Change, Revision 54 cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Douglas Pickett, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd.

Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601 Mr. E. William Brach Director Spent Fuel Project Office Office of Nuclear Material Safety & Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555

NRC DOCUMENT CONTROL DESK ATTACHMENT 1 Page 1 of 1 VERMONT YANKEE CONTROLLED DOCUMENT TRANSMITTAL FORM SECTION 1 DOCUMENT TITLE: EMERGENCY PLAN COPY NUMBER: 49 CHANGE NUMBER: 58 ISSUE DATE: 12/19/2013 INSTRUCTIONS:

a. Attached is an authorized controlled copy to the above listed document for retention as your assigned copy.

b. Review the revised material.

c. Incorporate new change into the controlled document by document issue date, if applicable.

d. Ensure that those who use this document are aware of the change.

e. Destroy all superseded pages.

f. Destroy obsolete forms and insert new forms into the files.

g. Sign and date this form and return to DCC within (7) seven business days.

h. Complete appropriate change information on VY Controlled Document Record of Changes.

i. See special instructions if applicable.

j. Cancellation of controlled document.

TRANSMITTED BY: Karen Ryan kryanl@entergy.com MC 1210 DCC SECTION 2 The undersigned acknowledges completion of the preceding instructions and any attachments.

Signature of Recipient: /

Print Name/Signature Date AFTER COMPLYING WITH THE ABOVE INSTRUCTIONS, RETURN TO DCC WITHIN 7 BUSINESS DAYS OF THE ISSUE DATE.

Special U.S. NUCLEAR REGULATORY COMMISSION, Attn: Document Control Desk, 11555 Rockville Pike, Rockville, Instructions: MD 20852

- This IS NOT a Quality Record -

AP-6805 DOCUMENT PROCESSING AND DISTRIBUTION ATTACHMENT 1 Rev. No. 2 Page 18 of 24

BVY 13-104 Docket No. 50-271 Attachment Vermont Yankee Nuclear Power Station Emergency Plan Change, Revision 54

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW (Typical)

Letter#: BVY 13-104 Response Due: N/A

Subject:

Emergency Plan Date Issued for Review: 12/19/13 Correspondence Preparer I Phone #: Justine Anderson 802-258-4160 Section I Letter Concurrence and Agreement to Perform Actions POSITION I NAME Action Signature (concurrence, certification, etc.) (sign, interoffice memo, e-mail, or telecom)

N/A N/A N/A COMMENTS Section II Correspondence Screening Does this letter contain commitments? If "yes," identify the commitments with due Yes LI dates in the submittal and in Section III. When fleet letters contain commitments, a No PCRS LO (e.g., LO-LAR, LO-WT) should be initiated with a CA assigned to each z applicable site to enter the commitments into the site's commitment management system.

Does this letter contain any information or analyses of new safety issues performed at NRC Yes EL request or to satisfy a regulatory requirement? If "yes," reflect requirement to update the No UFSAR in Section III. z Does this letter require any document changes (e.g., procedures, DBDs, FSAR, TS Bases, Yes El etc.), if approved? If "yes," indicate in Section III an action for the responsible No department to determine the affected documents. (The Correspondence Preparer z may indicate the specific documents requiring revision, if known or may initiate an action for review.) I __

EN-LI-106 REV 12

ATTACHMENT 9.4 NRC SUBMI'nAL REVIEW Does this letter contain information certified accurate? If "yes," identify the information Yes I and document certification in an attachment. (Attachment 9.5 must be used.) No Section III Actions and Commitments Required Actions Due Date Responsible Dept.

Note: Actions needed upon approvalshould be captured in the appropriateaction tracking system 12/16/13 Eplan Present to OSRC DCC Transmit Eplan to Merlin and send to NRC 12/19/13 Commitments Due Date Responsible Dept.

Note: When fleet letters contain commitments, a PCRS LO should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.

N/A Section IV Final Document Signoff for Submittal Correspondence Preparer Justine Anderson 12/3/13 Final Submittal Review (optional)

Responsible Department Head P McKenney

/

I r EN-LI-106 REV 12

NEW CONTROLLED DOCUMENT AND REVISION REQUEST FORM Page I of 1 ATIACIHME1T - NEW CONTROLLED DOCUMENT AND Vi-mL(l, SEICI'[N ONERe11quest for Curent Document (Completed by Controlled Doculient Owner)

(A) Controlled Document1Uae (a) Current Revision Number (C) Spon*Mng Orgaltlzatlon D) Typing Completion Needed (Date) Hard Copy (Allow suflclentp~hl 1 ¶o fe for DCC personnel) 10Electronic (F) Originatoi Name (Print) Orl inatorrS;1giba--ure - Date of n I.:;P11"1-U-?0%4 92%=0e.NWQ Request for Cdrgton of Co-- rolled Document (Completed by Cntrolled Document Owner)

1. Justification for Controlled Document Status (Check Applicable Box)

NRC mandate

• Audit requirement Administrative guideline OthEr

2. Ust Controlled Document Custodians

[(A)

SECTIONTHR DCC S First Draft TypIng(Completed by cDo)

Date Received 1(3) Draft Completed by I(C) Date Draft Completed SECTI ON FUW R Approval and D hbutltn (Completed bj Controlled Document Owner)

(A) Proofread by Originator (pnlnt/ulgn/date)N (8) Distribution Submission Date (C) Date Required for Imu ifective Date)

(10) ten business days from date)

IDI 5(Allow (0) Safety Evaluation Per EN-L.-100, Process Applicability Determination and EN-U-101, 10CFRS0.59 Review Program 5 0.59 Screening completed and attached, Safety Evaluation NOT required 50.59 Evaluation completed and attached (E) iCFR50.S4(q) Evaluation Emergency Plan: 10CFRS0.S4(q) evaluation completed per EN-EP-305 and attached N/A (F) Engineering Change (EC) or DRNS to be Incorporated:

SECTION F.EeI Distribution (Completed by CDI)

[Date Distributed ) ITransmlttal* bC!cj-"-, Change .

This n a Quality Record. m A -

AP-6805 R

Rev. No. _g DOCUMENT PROCESSING AND DISTRIBUTION ATTACHMENT 6 Page 23 of 24 I U

Memorandum DATE: December 19, 2013 TO: NRC FROM: Michael P. McKenney, Manager, Emergency Planning

SUBJECT:

Emergency Plan Revision 54 INTRODUCTION:

The latest revision to the Emergency Plan is comprised of a changes that do not reduce 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 EN-LI-100 Process Applicability Determination indicates that changes to the E-Plan are evaluated through the 50.54(q) process. A 10 CFR 50.54(q) Screening and Evaluation are attached.

CHANGE

SUMMARY

Index

• Added 7.1 InForm Notification System 3.2. Actions in an Emergency

• Changed the words Nuclear Alert System (NAS) to Emergency Notification System in step 5 because the NAS phones are no longer the primary offsite notification method. The term Emergency Notification System now refers to the InForm Notification System, NAS phones, or backup commercial telephones and radios.

6.2.6. Facilities and Equipment for Offsite Monitoring

• The specific reference to the James A. Fitzpatrick environmental laboratory has been removed from this section. A range of supporting laboratories are available to support Vermont Yankee during a declared emergency.

7.1, InForm Notification System 0 Added a description for the new InForm Notification System.

7.2. Nuclear Alert System

• Changed the words "Is used" to "can be used" to describe the use of the Nuclear Alert System (NAS) phones during an emergency.

Figure 7.1, Plant to State Notification Channels

• Added a line to show the InForm Notification System as the primary notification channel to the States.

Figure 7.2, Coordination Channels with States

• Added a line to show the InForm Notification System as the primary notification channel to the States.

Section 8.1. Normal Plant Organization

• Removed the Field Support Supervisor from the Normal Plant Organization.

Table 8.4, Minimum Staffing Requirements for the ENVY ERO

" Notification/Communication: Changed the responsibility from the Chem Tech to an Auxiliary Operator (AO)

• Radiological Accident Assessment - Deleted the Field Support Supervisor (FSS) and added a Chem Tech.

• Note 4 - Deleted the FSS and added a Chem Tech to the qualified individuals to perform dose assessment.

Figure 8.1, Normal On-Shift Emergency Organization

• Revised to match the shift staffing listed in section 8.1. The Field Support Supervisor (FSS) has been removed.

Figure 9.1, Notification Plan

• Changed Nuclear Alert System (NAS) to InForm/NAS because both InForm and the NAS phones can be used for performing offsite notifications.

Appendix E. Letters of Agreement

• Letters of Agreement have been removed from this document and will be maintained in the Emergency Plan Department files. A cross reference and a summary of the agreements has been added.

Appendix F, Evacuation Time Estimates

• The summary of the evacuation time estimate (ETE) has been removed from this appendix and a cross reference has been created to reference the original document performed by a contract company for all Entergy sites.

Appendix G, Index of Emergency Plan Implementing Procedures and Support Plans

" Updated procedure numbers to match the procedure upgrade project numbering.

" Added the Evacuation Time Estimate to Support Plans.

dNUCLEAR QUALITY RELATED EN-LI-113 REV. 9

-Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 1 OF 3 Licensing Basis Document Change Process ATTACHMENT 9.1 LBDCR FORM (TYPICAL)

I. LBDCR INITIATION Justine Anderson Eplan 4160 VY 12/3/13 LIC 13-12 INITIATOR'S NAME DEPARTMENT PHONE UNIT DATE LBDCR #

(printortype)

DESCRIPTION OF THE CHANGE (Attach additional pages if necessary; may also reference PAD Form.)

Changes are listed on the PAD Form LiCENSING DOCUMENT(S) AFFECTED- AFFECTED SECTIONIPAGE(S)

__(Attach marked-up pages)

El Operating License (OL)

[I Technical Specifications (TS)

El Environmental Protection Plan (EPP)

E] Anti-Trust Conditions (Appendix of OL)

El NRC Orders El Updated Final Safety Analysis Report (UFSAR)

El TS Bases El Technical Requirements Manual (TRM) (including TRM Bases)

El Quality Assurance Program Manual (QAPM)

El Security Plan Index, 3.2, 6.2.6, 7.1, 7.2, 0 Emergency Plan (EP) Figure 7.1 & 7.2, 8.1, Table 8.4, Figure 8.1, Figure 9.1, Appendix E, F & G El Offsite Dose Calculation Manual (ODCM)

El Spent Fuel Storage Cask Final Safety Analysis Report (CFSAR)

El Spent Fuel Storage Cask Certificate of Compliance (CoC)

E] Spent Fuel Storage Cask CoC Bases Ej 10 CFR 72.212 Evaluation Report (212 Report)

E Fire Protection Program (FPP)IFire Hazards Analysis (FHA)

El Core Operating Limits Report (COLR)

I] Other (Specify)

EN-LI-113 Rev. 9

I SE Entrir, NUCLEAR MANAGEMENT MANUAL I

QUALITY RELATED INFORMATIONAL USE EN-LI-113 PAGE 2 OF 3 REV.9 Licensing Basis Document Change Process ATTACHMENT 9.1 LBDCR FORM METHOD(S) ALLOWING THE CHANGE *

[ PAD Review (Attach a copy) E] 10 CFR 50.48 / EN-DC-128 Review (Attach a copy)

El 10 CFR 50.59 Evaluation (Attach a copy) [ 10 CFR 50.54 Review (Attach a copy)

El 10 CFR 72.48 Evaluation (Attach a copy) El Environmental Evaluation (Attach a copy)

E] Approved NRC Change (Attach a copy of El Editorial Change (LBDs controlled under 50.59 or NRC Letter or reference NRC letter number) 72.48, only)

El NRC Approval is Required El Other Approval (Attach a copy of supporting documents)

El "UFSAR-only" Change (NEI 98-03)

Check the appropriate box below:

El Reformatting El Replacing Detailed Drawing El Referencing other Documents Check the appropriate box below and provide a basis for removing information, if applicable:

El Removing Excessive Detail El Removing Obsolete Information El Removing Redundant Information El Removing Commitments Removal Basis:

II. LBDCR IMPLEMENTATION' ACTIONS SUPPORTING IMPLEMENTATION REQUIRED ACTIONS ACTION TAKEN OR LB ECINTRACKING METHOD ACTION RESP. DEPT Index, 3.2, 7.1, Revise Implementinq Eplan PRVRY-2013-305; 353; 423; 7.2, Figure 7.1 & Procedures in conjunction with 369; 388; 442; 316 & 464 7.2, 8.1, Table the Eplan chanaqe 8.4, Figure 8.1, Figure 9.1 Same as above Train Chem Techs and AOs Training TEAR 2013-301 & 528 N/A Send Eplan & Procedures to DCC BVY 13-103 & 104 NRC EN-LI-1 13 Rev. 9

III. LBDCR REVIEW AND APPROVAL 1 REVIEW AND APPROVAL. of LBDCR" (see Attachment 9.2)

Department Approved 2 Date UFSAR Section Owner 3 N/A Peer Review 4 Phil Couture per telecom 12/3/13 LBD Owner Add additional table rows as needed.

2 The printed name should be included on the form when using electronic means for signature.

Signatures may be obtained via electronic processes (e.g., PCRS, ER processes, Asset Suite signature), manual methods (e.g., ink signature), e-mail, or telecommunication. If using an e-mail, attach it to this form.

UFSAR Section Owners should refer to EN-LI-1 13-01, "Updated Final Safety Analysis Report Change Process," for review expectations. N/A if change does not update the UFSAR.

Administrative peer review intended to verify changes have been incorporated correctly into revised LBD prior to issuance.

EN-LI-113 Rev. 9

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM I. OVERVIEW PAD Rev. #: 0 Facility: Vermont Yankee Proposed Activity / Document: Emergency Plan ChangelRev. #: 54 Description of Proposed Activity:

Index

, Added 7.1 InForm Notification System 3.2. Actions in an Emergency

• Changed Nuclear Alert System to Emergency Notification System in step 5 for notifying the three states 6.2.6. Facilities and Equipment for Offsite Monitoring

• Removed the reference to the James A. Fitzpatrick environmental laboratory 7.1. InForm Notification System 0 Added a description for the InForm Notification System 7.2. Nuclear Alert System

• Changed the words "Is used" to "can be" used to describe the Nuclear Alert System Figure 7.1. Plant to State Notification Channels

• Added a line for Inform Figure 7.2. Coordination Channels with States

• Added a line for Inform Section 8.1. Normal Plant Organization

• Removed the Field Support Supervisor from the Normal Plant Organization Table 8.4. Minimum Staffing Requirements for the ENVY ERO

" Notification/Communication: changed Chem Tech to AO

" Radiological Accident Assessment - Deleted Field Support Supervisor (FSS) and added Chem Tech.

• Note 4 - Deleted FSS and added Chem Tech Figure 8.1, Normal On-Shift Emergency Organization

• Revised to match shift staffing in section 8.1 and remove the Field Support Supervisor (FSS)

Figure 9.1. Notification Plan

• Changed NAS to Inform/NAS Appendix E. Letters of Agreement

• Letters of Agreement have been removed from this document and will be maintained in the Emergency Plan Department files. A summary of the agreements has also been added.

Appendix F. Evacuation Time Estimates

• An evacuation time estimate summary has been removed from this document and the entire document is maintained separately and referenced in this appendix.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM Appendix G. Index of Emeraqency Plan lmplementinq Procedures and Support Plans

" Updated procedure numbers to match the procedure upgrade project numbering

• Added the Evacuation Time Estimate to Support Plans II. DOCUMENT REVIEW Provide the requested information for each item below.

1. For documents available electronically:

a. List search engine or documents searched, and keywords used:

Documents Searched: UFSAR Rev 26, Emergency Plan (C. 1970, 1978, Rev 36, Rev 37, Rev 38, Rev 45, Rev 53)

Keywords used: InForm, Notification, Nuclear Alert System, NAS, Field Support Supervisor, Dose Assessment, Communication, Chemistry Tech, Auxiliary Operator, Letters of Agreement, Memorandum of Understanding, Evacuation Time Estimate, EPIP, Implementing Procedures, Lab

b. List relevant sections of controlled electronic documents reviewed:

UFSAR - Section 13.6, Emergency Plan Emergency Plan(s) - Entire documents searched for the above keywords. Applicable sections include Sections 3, 7, 8, 11 and Appendices D, F and G.

2. Documents reviewed manually (hardcopy):

Emergency Plan Rev 53: Figure 4.1, 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, 4.8, 6.1, 6.2, 6.3, 6.4, 7.1, 7.2, 8.1, 8.2, 8.3, 8.4, 8.5, 8.7, 9.1, 10.1, 10.2 & 10.3

3. For those documents that are not reviewed either electronically or manually, use the specific questions provided in Sections III and IV of Attachment 9.2 of EN-LI-100 as needed. Document below the extent to which the Attachment 9.2 questions were used.

For LBDs not searched electronically or manually the questions in Attachment 9.2 were reviewed and no LBD changes were identified.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM Ill. PROCESS REVIEW Does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following processes? Associated regulations and procedures are identified with each process below.

• :::*....

• i* o T....

PROCESS (Regulations I Procedures YES'. NO REVIEW RESULTS Chemistry I Effluents 0] 0 Radwaste I Process Control Program (PCP) 0 0 (EN-RW-105 or contact the Radiation Protection Dept.)

Radiation Protection I ALARA 0 0 (10 CFR 20 / EN-RP-1 10 or contact the Radiation Protection Dept.)

Inservice Inspection Program (10 CFR 50.55a / EN-DC-120, -351) I] 0 Inservice Testing Program (10 CFR 50.55a / EN-DC-332) 0 0 Maintenance Rule Program (10 CFR 50.65/ EN-DC-203, -204, -205, -206, 0 0

-207)

Containment Leakage Rate Testing (Appendix J) Program (10 CFR 50 El 0 Appendix J / EN-DC-334)

IF any box is checked "Yes," THEN contact the appropriate department to ensure that the proposed change is acceptable and document the results in the REVIEW RESULTS column.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM IV. LICENSING BASIS DOCUMENT REVIEW Does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Document(s)? Associated regulations and procedures are identified with each Licensing Basis Document below.

LICENSING BASIS DOCUMENTS YES NO REVIEW RESULTS OR SECTIONS (Regulations I Procedures) AFFECTED OR LBDCR #

Quality Assurance Program Manual (QAPM) 01 0 (10 CFR 50.54(a) / EN-QV-104)

Fire Protection Program (FPP) [includes the Fire Safety Analysis/Fire Hazards Analysis (FSA/FHA)] 01 0 OL Condition, 10 CFR 50.48 / EN-DC-128)

Emergency Plan (10 CFR 50.54(q) / EN-EP-305) 0 0 Screened lAW EN-EP-305 Environmental Protection Plan (Appendix B of the OL, Environmental Evaluation / EN-EV-115, EN-EV-117, 11 0 No EPP at VY EN-LI-1i03)

Security Plan and Cyber Security Plan 0 0

[10 CFR 50.54(p) / EN-NS-210 or contact the site Security / IT Dept.]

Operating License (OL) I Technical Specifications (TS) D* 0 (10 CFR 50.90 / EN-LI-103)

TS Bases (10 CFR 50.59 / EN-LI-100 / EN-LI-101) 0l 0 Technical Requirements Manual (TRM) (Including TRM Bases) 11 09 (10 CFR 50.59 / EN-LI-100 / EN-Li--101)

Core Operating Limits Report (COLR), and Pressure and Temperature Limits Report (PTLR) (TS Administrative Controls, EN-LI-113, EN-LI-100, El 0 EN-LI-1i01)

Offsite Dose Calculation Manual (ODCM)

(TS Administrative Controls or 10 CFR 50.59 / EN-LI-113 or EN-LI-100 / El 0 EN-LI-101)

Updated Final Safety Analysis Report (UFSAR)

(10 CFR 50.71(e) / EN-LI-1 13, EN-Li-100, EN-LI--101)

Storage Cask Certificate of Compliance (10 CFR 72.244 / EN-LI-1 13) 1?* 0 Cask FSAR (CFSAR) (including the CTS Bases) 11 (10 CFR 72.70 or 72.248 / EN-Li-1 13, EN-LI-100,EN-LI-1 12) 10 CFR 72.212 Evaluation Report (212 Report) El 0 (10 CFR 72.48 / EN-LI-100, EN-Li-1 12)

NRC Orders (10 CFR 50.90 / EN-LI-103 or as directed by the Order) E* 0 NRC Commitments and Obligations (EN-LI-110) E* 0 Site Specific CFR Exemption D*

(10 CFR 50.12, 10 CFR 55.11, 10 CFR 55.13, 10 CFR 72.7)

• Contact the site Licensing Department if needed.

IF any box is checked "Yes," THEN ensure that any required regulatory reviews are performed in accordance with the referenced procedures. Prepare an LBDCR per procedure EN-LI-113 if a LBD is to be changed, and document any affected sections or the LBDCR #. Briefly discuss how the LBD is affected in Section VII.A.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM V. 10 CFR 50.59 1 10 CFR 72.48 APPLICABILITY Can the proposed activity be dispositioned by one of the following criteria? Check the appropriate box (if any).

El An approved, valid 50.59172.48 Evaluation covering associated aspects of the proposed activity already exists. Reference 50.59/72.48 Evaluation # (if applicable) or attach documentation. Verify the previous 50.59/72.48 Evaluation remains valid.

El The NRC has approved the proposed activity or portions thereof or a license amendment being reviewed by the NRC addresses the proposed activity. Reference the approval document:

[ The proposed activity is controlled by one or more specific regulations.

Examples of specific regulations are:

• Maintenance Rule (50.65),

• Quality Assurance Program (10 CFR 50 Appendix B)

• Security Plan (50.54(p))

" Emergency Plan (50.54(q))

• Fire Protection (operating license condition)

See NEI 96-07 Section 4.1 for additional guidance on specific regulations.

Reference the controlling specific regulation(s): 50.54(q)

IF the entire proposed activity can be dispositioned by the criteria in Section V, THEN 50.59 and 72.48 Screenings are not required. Proceed to Section VII and provide basis for conclusion in Section VII.A.

Otherwise, continue to Section VI to perform a 50.59 and/or 72.48 Screening, or perform a 50.59 and/or 72.48 Evaluation in accordance with EN-LI-101 and/or EN-LI-112.

Changes to the IPEC Unit I Decommissioning Plan are to be evaluated in accordance with the 50.59 process, as allowed by the NRC in a letter to IPEC dated January 31, 1996. [lPEC-1 Letter RA960014]

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM VI. 50.59 / 72.48 SCREENING REVIEW VI.A 50.59172.48 SCREENING (Check the appropriate boxes.)

El 10 CFR 50.59 Screening criteria are met [10 CFR 50.59(c)(1)]

The proposed activity meets all of the following criteria regarding design function:

• Does not adversely affect the design function of an SSC as described in the UFSAR; AND

• Does not adversely affect a method of performing or controlling a design function of an SSC as described in the UFSAR; AND

" Does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC will be accomplished as described in the UFSAR; AND

• Does not involve a test or experiment not described in the UFSAR.

El The proposed activity does not involve structures, systems, or components controlled by 10 CFR 50.59.

El 10 CFR 72.48 Screening criteria are met. [10 CFR 72.48(c)(1)] (Applicable to sites with an ISFSI)

The proposed activity meets all of the following criteria regarding design function:

• Does not adversely affect the design function of an SSC as described in the CFSAR; AND

• Does not adversely affect a method of performing or controlling a design function of an SSC as described in the CFSAR; AND

• Does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC will be accomplished as described in the CFSAR; AND

• Does not involve a test or experiment not described in the CFSAR.

El The proposed activity does not involve structures, systems, or components controlled by 10 CFR 72.48.

IF either of the 50.59 or 72.48 Screening criteria are met, THEN complete VI.B below as appropriate and proceed to Section VII.

IF the proposed activity does not meet the applicable criteria, THEN perform a 50.59 or 72.48 Evaluation in accordance with EN-LI-101 or EN-LI-112, as appropriate, attach a copy of the Evaluation to this form, and proceed to Section VII.

IF the activity does not involve systems, structures, or components controlled by 10 CFR 50.59 or by 10 CFR 72.48, THEN a 50.59 or 72.48 Screening is not required, as appropriate, and proceed to Section VII.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM VI.B BASIS Provide a clear, concise basis for determining the proposed activity may be screened out such that a third-party reviewer can reach the same conclusions. Refer to NEI 96-07 Section 4.2 for guidance. Provide supporting documentation or references as appropriate.

VII. REGULATORY REVIEW

SUMMARY

VII.A GENERAL REVIEW COMMENTS (Provide pertinent review details and basis for conclusions if not addressed elsewhere in form.)

In this revision to the Emergency Plan the following changes are taking place:

" The Nuclear Alert System (NAS) Phone is being replaced by the InForm Notification System as the primary offsite notification system.

" The specific reference to the James A. Fitzpatrick environmental laboratory was removed

" Revised the on shift staff to eliminate the Field Support Supervisor and re-assign on shift responsibilities including dose assessment, and offsite notification/communication

• Relocated the Letters of Agreement with offsite agencies to the Emergency Planning Department files

" Removed the Evacuation Time Estimate summary and created a cross reference to the entire document

• Updated procedure numbers and support references The Nuclear Alert System (NAS) Phone is changing from the primary to the secondary method for performing emergency notifications with offsite agencies in VT, NH and MA. The InForm Notification System will be used as the primary emergency notification system on the date that Revision 54 of the Emergency Plan is effective in Merlin and the NAS phone will then become the backup notification method. InForm consists of source and destination computers that take advantage of the intemet to send emergency notification forms during declared emergencies and drills/exercises. The destination computers are staffed 24/7 in the Control Room and at the State Police dispatching points for VT, NH and MA. InForm performs self checks every 10 seconds to ensure all source and destination computers are online and available for use. A time motion study was conducted on 11/21/13 to ensure that the Shift Technical Advisor can complete the notification form and send the emergency notification to the States using InForm within the 15 minute requirement described in 10CFR50.47(b)(5) and (6). The results of the time motion study indicate that the required notification can be completed, approved and sent to the States in 117 seconds. Sections 3.2 "Actions in an Emergency", 7.1 "InForm Notification System", 7.2 "Nuclear Alert System" and Figures 7.1 " Plant to State Notifications Channel", 7.2 "Coordination Channel with States" & 9.1 "Notification Plan" have been revised in the Emergency Plan to reflect the new InForm Notification System. A review of the historical revisions to the Emergency Plan ranging from 1970 - 2013 have revealed that telephones and radios have been maintained as the primary and secondary EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM communication methods prior to the adoption of InForm. On the date that this Emergency Plan revision is effective in Merlin, InForm will become the primary method, with the NAS phone as the first backup followed by commercial phones and radios. All of these methods are available for use in the Control Room and at the Emergency Operations Facility (EOF).

The reference to the James A. Fitzpatrick (JAF) environmental laboratory has been removed from Section 6.2.6 "Facilities and Equipment for Offsite Monitoring" of the Emergency Plan. This section clearly states "Vermont Yankee has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities through INPO." The specific reference to the JAF lab has been removed because this location is not designated as a primary facility and therefore there is no need to reference it specifically when there are a range of options available and none of the other locations are listed individually. The capability to access outside analytical assistance and laboratory facilities remains unchanged. Historically the capability to obtain analytical assistance has been performed at the environmental laboratory in Westboro MA, which was removed from the Emergency Plan in Rev 50 because the location went out of business. The capability to obtain analytical assistance is now available through other Entergy sites, State and Federal agencies and other utilities through INPO.

The On Shift Staff listed in Section 8.1 "Normal On-Shift Emergency Organization", Table 8.4 "Minimum Staffing Requirements for the ENVY ERO" and Figure 8.1 "Normal On-Shift Emergency Organization" have been revised to remove the Field Support Supervisor (FSS), and re-assign the on shift responsibilities for the Chemistry Technician and the Auxiliary Operator (AO). The Field Support Supervisor was added to the Emergency Plan in Revision 52 as a result of the On-Shift Staffing Analysis performed in December 2012. The primary responsibility of the FSS as a result of the staffing analysis was to perform initial dose assessment activities in order to relieve the burden on the Shift Manager during a safe shutdown scenario with control room evacuation. In order to remove the FSS from the minimum shift staffing a time motion study was performed with each operating crew to determine if the required actions could be performed with three (3) operators instead of four (4). In order to be successful all crews needed to perform the tasks in 21.33 minutes. The results indicated that the procedure steps can be successfully completed in times ranging from 14 minutes 43 seconds to 19 minutes and 48 seconds.

Upon successful testing it was determined that the FSS can be removed from the minimum shift staff.

The responsibility for performing initial dose assessment has been transferred to the on shift Chemistry Technician from the FSS. All of the Chemistry Technicians have been trained to perform the dose assessment activities as a preparation for this change. The responsibility for activating the emergency response organization notification system and performing offsite notifications has been transferred from the Chemistry Technician to an on shift Auxiliary Operator. All of the Auxiliary Operators have been trained to perform these tasks. The new responsibilities will be effective when Rev 54 of the Emergency Plan is effective in Merlin. A review of the historical revisions of the Emergency Plan indicates that Table 8.4 "Minimum Staffing Requirements for the ENVY ERO" was added to the plan in Rev 38 (9/24/03). In this revision, the Chemistry Technician was assigned the function of performing "notification/communication". On Shift AO's were assigned the functional tasks of "Plant Operations &

Assessment of Operational Aspects", "Repair & Corrective Actions", "Protective Actions" and "Fire Fighting". Since Rev 38 was in effect, the number of on shift AOs has increased from three (3) to six (6).

With the additional individuals on shift, all of the assigned functional tasks can be performed as designated in Rev 38 as well as the task of notification/communication that was previously assigned to the Chemistry Technician.

The Letters of Agreement contained in Appendix E have been removed from the Emergency Plan and will be maintained separately in the Emergency Planning Department files going forward. These letters have been removed so that they can be revised or updated without processing Emergency Plan revisions.

None of the letters have been revised as a result of this revision and all of the letters will be screened and EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM evaluated under the 10CFR50.54(q) review process when changes are necessary to ensure the effectiveness of the Emergency Plan is not reduced.

Appendix F "Evacuation Time Estimates" has been revised to remove the summary of the evacuation time estimate and create a cross reference to the entire document that is completed by an outside agency. The evacuation time estimate is completed by a contract agency and maintained in the Emergency Planning Department files. Copies of this study are also provided to the States of VT, NH and MA for use in their planning efforts. The creation of a cross reference to this document will eliminate the potential for errors in creating a summary and maintaining it separately from the original document.

Appendix G "Index of Emergency Plan Implementing Procedures and Support Plans" has been updated to reflect the most current procedure numbers for the Emergency Plan Implementing Procedures and the section for Support Plans has been updated to include a reference to the evacuation time estimate document.

A review of the UFSAR, Emergency Plan (current and historical revisions) and a review of the questions in EN-LI-100 Attachment 9.2 "PAD Form Instructions" indicates that the changes made to the Emergency Plan will not affect any of the other LBDs on this PAD form. A separate 10CFR50.54(q) Screening and Evaluation will be performed to determine if the changes maintain the effectiveness of the Emergency Plan and can be incorporated without prior NRC approval.

EN-LI-100 REV. 13

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM VII.B CONCLUSIONS

1. Is a change to an LBD being initiated? [] Yes IF "Yes," THEN enter the appropriate change control process and No include this form with the change package.

2. Is a 10 CFR 50.59 Evaluation required? Yes IF "Yes," THEN complete a 50.59 Evaluation in accordance with EN-LI- No 101 and attach a copy to the change activity.

3. Is a 10 CFR 72.48 Evaluation required? Yes IF "Yes," THEN complete a 72.48 Evaluation in accordance with EN-LI- No 112 and attach a copy to the change activity.

VIII. SIGNATURES 1 Preparer: Justine Anderson/ qyIENVYI E-Plan/ 12/3/13 Name (print) I Signature I Company I Department I Date Reviewer: Audra Perlman / J* - IAu0

/ Vermont Yankee / Training / 12/3/13 Name (print) I Signature I Company I Department I Date Process Applicability Exclusion Site Procedure N/A Champion or Name (print) I Signature I Company I Department I Date Owner:

Upon completion, forward this PAD form to the appropriate organization for record storage. If the PAD form is part of a process that requires transmittal of documentation, including PAD forms, for record storage, then the PAD form need not be forwarded separately.

The printed name, company, department, and date must be included on the form. Signatures may be obtained via electronic processes (e.g., PCRS, ER processes, Asset Suite signature), manual methods (e.g., ink signature), e-mail, or telecommunication. If using an e-mail, attach it to this form.

EN-LI-100 REV. 13

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 1 OF 4 Procedure/Document Number: Emergency Plan Revision: 54 Equipment/Facility/Other: Vermont Yankee

Title:

Vermont Yankee Emergency Plan Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

Index

, Added 7.1 InForm Notification System 3.2. Actions in an Emergency

• Changed Nuclear Alert System to Emergency Notification System in step 5 for notifying the three states 6.2.6. Facilities and Equipment for Offsite Monitoring a Removed the reference to the James A. Fitzpatrick environmental laboratory 7.1. InForm Notification System

• Added a description for the InForm Notification System 7.2. Nuclear Alert System

• Changed the words "Is used" to "can be" used to describe the Nuclear Alert System Figure 7.1. Plant to State Notification Channels

• Added a line for Inform Fi-gure 7.2. Coordination Channels with States a Added a line for Inform Section 8.1. Normal Plant Organization

• Removed the Field Support Supervisor from the Normal Plant Organization Table 8.4. Minimum Staffinq Requirements for the ENVY ERO

" Notification/Communication: changed Chem Tech to AO

" Radiological Accident Assessment - Deleted Field Support Supervisor (FSS) and added Chem Tech.

• Note 4 - Deleted FSS and added Chem Tech Figure 8.1. Normal On-Shift Emergency Organization

• Revised to match shift staffing in section 8.1 and remove the Field Support Supervisor (FSS)

Figqure 9.1. Notification Plan 0 Changed NAS to Inform/NAS Appendix E. Letters of Agreement

• Letters of Agreement have been removed from this document and will be maintained in the Emergency Plan Department files. A summary of the agreements has also been added.

Appendix F. Evacuation Time Estimates

• An evacuation time estimate summary has been removed from this document and the entire document is maintained separately and referenced in this appendix.

Appendix G. Index of Emergency Plan Implementing Procedures and Support Plans

• Updated procedure numbers to match the procedure upgrade project numbering

• Added the Evacuation Time Estimate to Support Plans tN-tII-'iUb lity J

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 2 OF 4 ProcedurelDocument Number: Emergency Plan Revision: 54 Equipment/FacilitylOther: Vermont Yankee

Title:

Vermont Yankee Emergency Plan Part II. Activity Previously Reviewed? EIYES 0 NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to Alert and Notification System Design Report? Evaluation is next part Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and proposed change is documented below. complete Part VI.

Justification:

El Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-1 00)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

APPLICABILITY CONCLUSION (9 If there are no controlling change processes, continue the 50.54(q)(3) Screening.

0i One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

EL One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10CFR50.54(q)

Part IV. Editorial Change E]YES [NO 50.54(q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and complete Part VI.

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section I1?

1. Responsibility for emergency response is assigned. [11 []

2. The response organization has the staff to respond and to augment staff on a continuing basis (2417 [

staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] [

4. The process for timely augmentation of onshift staff is established and maintained. [2]

5. Arrangements for requesting and using off site assistance have been made. [3]

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] El

7. A standard scheme of emergency classification and action levels is in use. [4] El EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 3 OF 4 ProcedurelDocument Number: Emergency Plan Revision: 54 EquipmentlFacilitylOther: Vermont Yankee

Title:

Vermont Yankee Emergency Plan

8. Procedures for notification of State and local governmental agencies are capable of alerting them of [

the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and *L Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6]

13. Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] El

15. Adequate facilities are maintained to support emergency response. [8]

16. Adequate equipment is maintained to support emergency response. [8]

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9]

18. A range of public PARs is available for implementation during emergencies. [10]

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. [10]

20. A range of protective actions is available for plant emergency workers during emergencies, including Li those for hostile action events.[10]

21. The resources for controlling radiological exposures for emergency workers are established. [11]

22. Arrangements are made for medical services for contaminated, injured individuals. [12]

23. Plans for recovery and reentry are developed. [13]

24. A drill and exercise program (including radiological, medical, health physics and other program areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, EJ maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [141

27. Training is provided to emergency responders. [15]

28. Responsibility for emergency plan development and review is established. [161

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] []

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 4 OF 4 Procedure/Document Number: Emergency Plan Revision: 54 EquipmentlFacilitylOther. Vermont Yankee TtieeVermont Yankee Emergency Plan *:: -

APPLICABILITY CONCLUSION U If no Part V criteria are checked, a 50.54(qX3) Evaluation Is NMT required; document the basis for conclusion below and complete Part VI.

_ Iif any..i_PwrtgV.J'rIa.ar_.checked. -aiLVl

• a.50.5,1*,.X3)- Evaluatiee*..

BASIS FOR CONCLUSION The jndex has been revised to include a section for-the InForm Notification System. The addition of this Item

_dn . h e th.hmaning!.. or mnten-ot the ~me* Plei, cange-any facitltles-orequipment or change any of the processes described in the Emergency Plan. Updates to the table of contents to match the body of the Emergency Plan are administrative in nature and no further evaluation is required.

Appendix G: The revision of Appendix G 'Index of Emergency Plan Implementing Procedures and Support Plano" pf the Site Emarernn lpnr to inra*n ar na Iamkde.a i rforns n"1'i" Itoh tiva: to Time Estimate does not impact any of the 10 CFR 50.47(b) planning standard functions or program elements listed in Part V of this form. Referencing the Emergency Plan Implementing Procedures and the Evacuation Time Estimate does not alter the meaning or intent of the Emergency Plan, change any facilities or equipment or change any of the processes described in the Emergency Plan. A reference to these documents is administrative in nature and no further evaluation Is required.

Emergency Planning Standard 10CFR50.47(b)(1), (2), (3). (5), (6), (8) & (10) and planning standard Selermentsl, 2, 3,.4, 5, 8,-1, 15, 16 &19 in Part V of this form are affectedby the rematning changes In Part I. A 10CFR50.54(q) Evaluation will be performed to determine whether the effectiveness of the Emergency Plan is reduced and prior NRC approval is required.

Part VI. Signatures:

Preparer Name (Print) Preparer Signature

- Justine Anderson (Optional) Reviewer Name (Print) Reviewer Signature Reviewer Name (Print)

Tom Sowdon Nuclear EP Project Manager Approver Name (Print) Approver S nature MP McKenney EP manager or designee EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET I OF 12 ProcedurelDocument Number: Emergency Plan I Revision: 54 Equipment/FacilitylOther: Vermont Yankee

Title:

Emergency Plan Part I. Description of Proposed Change:

3.2. Actions in an Emergency

• Changed Nuclear Alert System to Emergency Notification System in step 5 for notifying the three states 6.2.6, Facilities and Equipment for Offsite Monitoring

• Removed the reference to the James A. Fitzpatrick environmental laboratory 7.1. InForm Notification System

• Added a description for the InForm Notification System 7.2. Nuclear Alert System

• Changed the words "Is used" to "can be" used to describe the Nuclear Alert System Figure 7.1. Plant to State Notification Channels

• Added a line for Inform Fiqure 7.2. Coordination Channels with States

• Added a line for Inform Section 8.1. Normal Plant Organization

• Removed the Field Support Supervisor from the Normal Plant Organization Table 8.4. Minimum Staffing Reguirements for the ENVY ERO

• Notification/Communication: changed Chem Tech to AO

• Radiological Accident Assessment - Deleted Field Support Supervisor (FSS) and added Chem Tech.

• Note 4 - Deleted FSS and added Chem Tech Figure 8.1, Normal On-Shift Emergency Organization

• Revised to match shift staffing in section 8.1 and remove the Field Support Supervisor (FSS)

Figure 9.1. Notification Plan

• Changed NAS to Inform/NAS Appendix E, Letters of Agreement

• Letters of Agreement have been removed from this document and will be maintained inthe Emergency Plan Department files. A summary of the agreements has also been added.

Appendix F, Evacuation Time Estimates

• An evacuation time estimate summary has been removed from this document and the entire document is maintained separately and referenced in this appendix.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 2 OF 12 Procedure/Document Number: Emergency Plan I Revision: 54 EquipmentlFacility/Other: Vermont Yankee

Title:

Emergency Plan Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

A process applicability determination (PAD) has been performed for Rev 54 of the Emergency Plan in accordance with EN-LI-1 00, Process Applicability Determination. The Emergency Plan (C. 1970, 1978, Rev 36, Rev 37, Rev 38, Rev 45, Rev 53) and the UFSAR Rev 26 were searched for the keywords: InForm, Notification, Nuclear Alert System, NAS, Field Support Supervisor, Dose Assessment, Communication, Chemistry Tech, Auxiliary Operator, Letters of Agreement, Memorandum of Understanding, Evacuation Time Estimate, EPIP, Implementing Procedures, Lab. The relevant historical sections of the Emergency Plan are listed below. None of the other licensing based documents on the PAD form were affected by this Emergency Plan change.

Emergency Plan section of the FSAR dated 04/15/1970 & 1012111978 -These documents have been reviewed against the changes being made in Rev 54.

Notification: The Emergency Director is responsible for notifying the State Police of emergencies via telephone or radio.

Dose Assessment: The Emergency Director is responsible for dose assessment.

Erplan Implementinq Procedures: There is no listing of the Implementing Procedures or support plans.

Evacuation Time Estimates: No listing of the evacuation time estimate.

Field Support Supervisor: Not referenced.

Laboratory: No reference to a lab.

Letters of Agreement: There are no specific copies of the letters of agreement available for reference, just a cross reference to an appendix containing agreements with offsite agencies.

On Shift Staff: There is no minimum staffing table to compare the on-shift staff that was maintained during this timeframe.

Emergency Plan Revision 36 dated 711812002 - This document was reviewed against the changes being made in Rev 54:

Notification: The Emergency Director is responsible for notifying the State Police of emergencies via NAS phone, commercial telephone or radio.

Dose Assessment: The Emergency Director is responsible for dose assessment.

Eplan Implementing Procedures: Listed in Appendix G Evacuation Time Estimates: A summary of the Evacuation Time Estimate document is maintained in Appendix F Field Support Supervisor: Not referenced.

Laboratory: Westboro MA Letters of Agreement: Appendix D, Duke Engineering Services and Mutual Assistance Agreement and Appendix E, Letters of Agreement On Shift Staff: There is no minimum staffing table. Section 8.1 references 1 Shift Supervisor, 1 Control Room Supervisor, 2 Control Room Operators, 2 Auxiliary Operators, 1 Shift Engineer, 1 RP, and 1 Chemistry Technician.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFRSO.54(q) EVALUATION SHEET 3 OF 12 Procedure/Document Number: Emergency Plan I Revision: 54 Equipment/FacilitylOther: Vermont Yankee

Title:

Emergency Plan Emergency Plan Revision 37 dated 12126/2002 - This document was reviewed against the changes being made in Rev 54.

Notification: The Emergency Director is responsible for notifying the State Police of emergencies via NAS phone, commercial telephone or radio.

Dose Assessment: The Emergency Director is responsible for dose assessment.

Eplan Implementing Procedures: Listed in Appendix G Evacuation Time Estimates: A summary of the Evacuation Time Estimate document is maintained in Appendix F Field Support Supervisor: Not referenced.

Laboratory: Westboro MA Letters of Agreement: Appendix D, Duke Engineering Services and Mutual Assistance Agreement and Appendix E, Letters of Agreement On Shift Staff: There is no minimum staffing table. Section 8.1 references 1 Shift Supervisor, 1 Control Room Supervisor, 2 Control Room Operators, 2 Auxiliary Operators, 1 Shift Engineer, 1 RP, and 1 Chemistry Technician.

Emergency Plan Revision 38 dated 9/24/2003 - This document was reviewed against the changes being made in Rev 54 Notification: The Emergency Director is responsible for notifying the State Police of emergencies via NAS phone, commercial telephone or radio.

Dose Assessment: The Emergency Director is responsible for dose assessment. SCRO and STA also qualified.

Eplan Implementing Procedures: Listed in Appendix G Evacuation Time Estimates: A summary of the Evacuation Time Estimate document is maintained in Appendix F Field Support Supervisor: Not referenced.

Laboratory: Westboro MA Letters of Agreement: Appendix D, Duke Engineering Services and Mutual Assistance Agreement and Appendix E, Letters of Agreement On Shift Staff: The minimum staffing table lists assignments of responsibilities. Section 8.1 references I Shift Manager, 1 Control Room Supervisor, 2 Control Room Operators, 3 Auxiliary Operators, 1 Shift Technical Advisor, 1 RP, and 1 Chemistry Technician.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 4 OF 12 Procedure/Document Number: Emergency Plan 7Revision: 54 Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan Emergency Plan Revision 45 dated 8121/2008 - This document was reviewed against the changes being made in Rev 54.

Notification: The Emergency Director is responsible for notifying the State Police of emergencies via NAS phone, commercial telephone or radio.

Dose Assessment: The Emergency Director is responsible for dose assessment. SCRO and STA also qualified.

Eplan Implementing Procedures: Listed in Appendix G Evacuation Time Estimates: A summary of the Evacuation Time Estimate document is maintained in Appendix F Field Support Supervisor: Not referenced.

Laboratory: Westboro MA Letters of Agreement: Appendix D, Environmental Laboratory Analytical and Dosimetry Services and Appendix E, Letters of Agreement On Shift Staff: The minimum staffing table lists assignments of responsibilities. Section 8.1 references 1 Shift Manager, 1 Control Room Supervisor, 2 Control Room Operators, 3 Auxiliary Operators, 1 Shift Technical Advisor, 1 RP, and 1 Chemistry Technician.

Emergency Plan Revision 53 dated 9/17/2013 - This document was reviewed against the changes being made in Rev 54.

Notification: The Emergency Director is responsible for notifying the State Police of emergencies via NAS phone, commercial telephone or radio.

Dose Assessment: The Emergency Director is responsible for dose assessment. SCRO, STA and FSS are also qualified.

Eplan Implementing Procedures: Listed in Appendix G Evacuation Time Estimates: A summary of the Evacuation Time Estimate document is maintained in Appendix F Field Support Supervisor: Referenced on shift and responsible for dose assessment.

Laboratory: Outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities through INPO Letters of Agreement: Appendix D, Environmental Laboratory Analytical and Dosimetry Services and Appendix E, Letters of Agreement On Shift Staff: The minimum staffing table lists assignments of responsibilities. Section 8.1 references I Shift Manager, 1 Control Room Supervisor, 2 Control Room Operators, 6 Auxiliary Operators, 1 Field Support Supervisor, 1 Shift Technical Advisor, I RP, and 1 Chemistry Technician.

Note: There is no approved SER for the Vermont Yankee Emergency Plan.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 5 OF 12 Procedure/Document Number: Emergency Plan I Revision: 54 Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

Previous NRC Commitments: Per EN-LI-1 10 the licensing management system used for tracking NRC commitments has been searched for items relating to the keywords: InForm, Notification, Nuclear Alert System, NAS, Field Support Supervisor, Dose Assessment, Communication, Chemistry Tech, Auxiliary Operator, Letters of Agreement, Memorandum of Understanding, Evacuation Time Estimate, EPIP, Implementing Procedures, Lab with no relevant results.

10 CFR 50.47 (b)(1) Assignment of Responsibility/Organizational Control 10 CFR 50.47 (b)(2) Onsite Emergency Organization 10CFR 50.47 (b)(5) - Emeraency Notifications 10 CFR 50.47 (b)(6) Emergency Communications Site Compliance: In the event of an emergency at Vermont Yankee the InForm Notification System is now used as the primary method for performing off-site emergency notifications. The Nuclear Alert System (NAS) phone will continue to utilized in the Control Room and the Emergency Operations Facility (EOF) as the backup communication method. In the event that both the primary and backup methods fail, commercial telephones and radios are also available for use in both locations. InForm consists of source and destination computers that take advantage of the internet to send emergency notification forms during declared emergencies and drills/exercises. The destination computers are staffed 24/7 in the Control Room and at the State Police dispatching points for VT, NH and MA. InForm performs self checks every 10 seconds to ensure all source and destination computers are online and available for use. A time motion study was conducted on 11/21/13 to ensure that the Shift Technical Advisor can complete the notification form and send the electronic emergency notification to the States using InForm within the 15 minute requirement described in 10CFR50.47(b)(5) and (6). The results of the time motion study indicate that the required notification can be completed, approved and sent to the States in 117 seconds. The Shift Technical Advisor (STA) is responsible for performing offsite notifications from the Control Room with approval from the Shift Manager, while the Offsite Communicator is responsible for performing the notifications from the EOF with approval from the Emergency Director.

Section 8.1 "Normal Plant Organization" and Table 8.4 "Minimum Staffing Requirements for the ENVY ERO" have been revised to remove the Field Support Supervisor (FSS) from the on-shift staff and re-assign the on shift responsibilities for notification/communications, dose assessment and safe shutdown during a Control Room evacuation. The FSS was added to the Emergency Plan in Revision 52 as a result of the On-Shift Staffing Analysis performed in December 2012. The primary responsibility of the FSS as a result of the staffing analysis was to perform initial dose assessment activities in order to relieve the burden on the Shift Manager during a safe shutdown scenario with Control Room evacuation.

In order to remove the FSS from the minimum shift staffing a time motion study was performed with each operating crew to determine if the required actions could be performed with three (3) operators instead of four (4). In order to be successful all crews needed to perform the tasks in 21.33 minutes. The results indicated that the procedure steps can be successfully completed in times ranging from 14 minutes 43 seconds to 19 minutes and 48 seconds. Successful testing has determined that the FSS can be removed from the minimum shift staff. The responsibility for performing initial dose assessment has been transferred to the on shift Chemistry Technician from the FSS. All of the Chemistry Technicians have been trained to perform the dose assessment activities as a preparation for this change. The responsibility for activating the emergency response organization notification system (ERONs) and performing offsite notifications has been transferred from the Chemistry Technician to an on shift Auxiliary Operator. All of the Auxiliary Operators have been trained to perform these tasks. All on shift responsibilities are established and assigned in accordance with Table 8.4.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 6 OF 12 ProcedurelDocument Number: Emergency Plan I Revision: 54 EquipmentlFacilitylOther: Vermont Yankee

Title:

Emergency Plan 10 CFR 50.47 (b)(3) Emerqency Response Support and Resources Site Compliance: Letters of agreement have been established with offsite groups to provide on-site aid in the event of an emergency situation, including those resulting from hostile action at Vermont Yankee.

These letters were previously maintained as an appendix to the Emergency Plan. As of the date of Rev 54 of the Emergency Plan these letters will be cross referenced in the Emergency Plan and maintained in the Emergency Planning Department files. None of the letters have changed as a result of this revision.

10 CFR 50.47 (b)(8) Emeraency Facilities and Equipment Site Compliance: In the event of an emergency at Vermont Yankee the site has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities through INPO. The specific reference to the James A. Fitzpatrick (JAF) environmental laboratory has been removed from Section 6.2.6 "Facilities and Equipment for Offsite Monitoring" of the Emergency Plan. The environmental lab at JAF is not designated as the primary facility for performing Vermont Yankee analytical services. There is no need to reference this lab specifically when there are a range of options available and none of the other locations are listed by title and location. The capability to access outside analytical assistance and laboratory facilities during an emergency remains unchanged.

10 CFR 50.47 (b)(10) Emergency Protective Actions Site Compliance: Evacuation time estimates are required for all nuclear power plants in accordance with NURGEG-0654 to support the formulation of protective action recommendations (PARs). Appendix F of the Emergency Plan has been revised to create a cross reference to the evacuation time estimate document and eliminate the summary that provided duplicate information.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR5O.54(q) EVALUATION ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 7 OF 12 ProcedurelDocument Number: Emergency Plan I Revision: 54 EquipmentlFacilitylOther: Vermont Yankee

Title:

Emergency Plan Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

10 CFR 50.47 (b)(1) Assignment of Responsibility/Organizational Control

• Responsibility for emergency response is assigned.

• The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan.

Sections IV.A. 1-9 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.A of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47 (b)(2) Onsite Emergency Organization

• The process ensures that on shift emergency response responsibilities are staffed and assigned.

• The process for timely augmentation of onshift staff is established and maintained.

Sections IV.A.2a-c and IV.C of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.B of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47 (b)(3) Emergency Response Support and Resources

• Arrangements for requesting and using off site assistance have been made.

Sections IV.A.6 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.C of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47 (b)(5) Emergency Notifications

• Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications.

Sections IV.D.3 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.E and Appendix 3 of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47 (b)(6) Emergency Communications

• Systems are established for prompt communication among principal emergency response organizations.

Sections IV.E.9 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.F of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47 (b)(8) Emergency Facilities and Eguipment

• Adequate facilities are maintained to support emergency response.

" Adequate equipment is maintained to support emergency response.

Informing criteria appear in Section II.H of NUREG-0654; NUREG-0696 "Functional Criteria for Emergency Response Facilities" and the licensee's emergency plan.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 8 OF 12 ProcedurelDocument Number: Emergency Plan I Revision: 54 EquipmentlFacilitylOther: Vermont Yankee

Title:

Emergency Plan 10 CFR 50.47 (b)(10) Emergency Protective Actions

• Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.

Appendix E to 10 CFR 50 does not contain any supporting requirements. Informing criteria appear in Section II.J and Supplement 3 of NUREG-0654 and the licensee's emergency plan.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 9 OF 12 ProcedurelDocument Number: Emergency Plan 7Revision: 54 Equipment/FacilitylOther: Vermont Yankee

Title:

Emergency Plan Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

The following changes are being evaluated in this revision to the Emergency Plan.

• The Nuclear Alert System (NAS) Phone is being replaced by the InForm Notification System as the primary offsite notification system. (Sections 3.2, 7.1 & 7.2, Figures 7.1, 7.2 & 9.1)

• The specific reference to the James A. Fitzpatrick environmental laboratory (Section 6.2.6)

" Revised the on shift staff to eliminate the Field Support Supervisor and re-assign on shift responsibilities including dose assessment, and offsite notification/communication (Section 8.1, Table 8.4 & Figure 8.1)

• Relocated the Letters of Agreement with offsite agencies to the Emergency Planning Department files (Appendix E)

" Removed the Evacuation Time Estimate summary and created a cross reference to the entire document (Appendix F)

In the event of an emergency at Vermont Yankee the InForm Notification System is now used as the primary method for performing off-site emergency notifications. The Nuclear Alert System (NAS) phone will continue to be utilized in the Control Room and the Emergency Operations Facility (EOF) as the backup communication method. In the event that both the primary and backup methods fail, commercial telephones and radios are also available for use in both locations. InForm consists of source and destination computers that take advantage of the internet to send emergency notification forms during declared emergencies and drills/exercises. The destination computers are staffed 24/7 in the Control Room and at the State Police dispatching points for VT, NH and MA. InForm performs self checks every 10 seconds to ensure all source and destination computers are online and available for use. A time motion study was conducted on 11/21/13 to ensure that the Shift Technical Advisor (STA) can complete the notification form and send the electronic emergency notification to the States using InForm within the 15 minute requirement described in 10CFR50.47(b)(5) and (6). The results of the time motion study indicate that the required notification can be completed, approved and sent to the States in 117 seconds which complies with the regulatory requirements. Sections 3.2 "Actions in an Emergency", 7.1 "InForm Notification System", 7.2 "Nuclear Alert System" and Figures 7.1 " Plant to State Notifications Channel", 7.2 "Coordination Channel with States" &

9.1 "Notification Plan" have been revised in the Emergency Plan to reflect the new InForm Notification System as the primary method of performing offsite notifications. A review of the historical revisions to the Emergency Plan ranging from 1970 - 2013 have revealed that telephones and radios have been maintained as the primary and secondary communication methods prior to the adoption of InForm. On the date that this Emergency Plan revision is effective in Merlin, InForm will become the primary method, with the NAS phone as the first backup followed by commercial phones and radios. All of these methods are available for use in the Control Room and at the Emergency Operations Facility (EOF). The assignment of responsibility (10CFR50.47(b)(1)) and the onsite emergency organization (10CFR50.54(b)(2)) continue to be in compliance with the regulations because the Shift Manager and the Emergency Director maintain overall authority for ensuring the offsite notifications are performed within 15 minutes of an emergency declaration (10CFR50.47(b)(5)). The STA and the Auxiliary Operators are trained and assigned the functions of notification/communication in the Control Room and the Offsite Communicator in the EOF is trained and assigned the responsibility for performing offsite notifications/communications once the EOF has relived the Control Room of their initial responsibilities. The requirements of 10CFR50.47(b)(1), (2), (5) and (6) continue to be met with the implementation of InForm as the primary notification system and this change does not represent a reduction in effectiveness to the Emergency Plan because all responsibilities continue to be assigned, training has been performed and system testing has been completed to ensure all time commitments can be met satisfactorily. This change can be implemented without prior NRC approval.

EN-EP-305 REV 3

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 10 OF 12 ProcedurelDocument Number: Emergency Plan I Revision: 54 Equipment/FacilitylOther: Vermont Yankee

Title:

Emergency Plan The reference to the James A. Fitzpatrick (JAF) environmental laboratory has been removed from Section 6.2.6 "Facilities and Equipment for Offsite Monitoring" of the Emergency Plan. This section clearly states "Vermont Yankee has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities through INPO." The specific reference to the JAF lab has been removed because this location is not designated as a primary facility and therefore there is no need to reference it specifically when there are a range of options available and none of the other locations are listed individually. The capability to access outside analytical assistance and laboratory facilities remains unchanged. Historically the capability to obtain analytical assistance has been performed at the environmental laboratory in Westboro MA, which was removed from the Emergency Plan in Rev 50 because the location went out of business. This section of the Emergency Plan continues to comply with the requirements of 10CFR50.47(b)(8), emergency facilities and equipment and does not represent a reduction in effectiveness to the Emergency Plan because facilities and equipment continue to be available with the capability to perform analytical assistance as requested during an emergency. This change can be implemented without prior NRC approval.

The On Shift Staff listed in Section 8.1 "Normal On-Shift Emergency Organization", Table 8.4 "Minimum Staffing Requirements for the ENVY ERO" and Figure 8.1 "Normal On-Shift Emergency Organization" has been revised to remove the Field Support Supervisor (FSS), and re-assign the on shift responsibilities for the Chemistry Technician and the Auxiliary Operator (AO). The Field Support Supervisor was added to the Emergency Plan in Revision 52 as a result of the On-Shift Staffing Analysis performed in December 2012. The primary responsibility of the FSS as a result of the staffing analysis was to perform initial dose assessment activities in order to relieve the burden on the Shift Manager during a safe shutdown scenario with control room evacuation. In order to remove the FSS from the minimum shift staffing, a time motion study was performed with each operating crew to determine if the required actions could be performed with three (3) operators instead of four (4). In order to be successful, all crews needed to perform the tasks in 21.33 minutes. The results indicated that the procedure steps can be successfully completed in times ranging from 14 minutes 43 seconds to 19 minutes and 48 seconds. Upon successful testing it was determined that the FSS can be removed from the minimum shift staff and all of the required actions can be completed with three (3) operators. The responsibility for performing initial dose assessment has been transferred to the on shift Chemistry Technician from the FSS. All of the Chemistry Technicians have been trained to perform the dose assessment activities as a preparation for this change. The responsibility for activating the emergency response organization notification system (ERONs) and performing offsite notifications has been transferred from the Chemistry Technician to an on shift Auxiliary Operator. All of the Auxiliary Operators have been trained to perform these tasks. The new responsibilities will be effective when Rev 54 of the Emergency Plan is effective in Merlin. A review of the historical revisions of the Emergency Plan indicates that Table 8.4 "Minimum Staffing Requirements for the ENVY ERO" was added to the plan in Rev 38 (9/24/03). In this revision (Rev 54), the Chemistry Technician was assigned the function of performing "notification/communication". On Shift AO's were assigned the functional tasks of "Plant Operations & Assessment of Operational Aspects", "Repair & Corrective Actions", "Protective Actions" and "Fire Fighting". Since Rev 38 went into effect, the number of on shift AOs has increased from three (3) to six (6). With the additional individuals on shift, all of the assigned functional tasks can be performed as designated in Rev 38 as well as the task of notification/communication that was previously assigned to the Chemistry Technician. The changes made in this revision to the on shift staff and the associated roles and responsibilities for each position continues to comply with planning standards 10CFR50.47(b)(1) & (2) and does not reduce the effectiveness of the Emergency Plan because the onsite emergency organization is established 24/7 and the roles and responsibilities for each position are assicned. All on shift individuals have EN-EP-305 REV 3

ATTACHMENT 9.2 IOCFR50.54(q) EVALUATION SHEET 11 OF 12 ProcedurelDocument Number: Emergency Plan 7Revision: 54 Equipment/FacilitylOther: Vermont Yankee

Title:

Emergency Plan been trained to perform their emergency functions and time motion studies have validated that the necessary actions can be performed using the minimum on shift staff. This change can be implemented without prior NRC approval.

The Letters of Agreement contained in Appendix E have been removed from the Emergency Plan and will be maintained separately in Merlin and the Emergency Planning Department files going forward with a cross reference to the letters appearing in Appendix E of the Emergency Plan. These letters have been removed so that they can be revised or updated without requiring a change to the entire Emergency Plan when no other changes are necessary. Letters of agreement are reviewed annually with the offsite agencies to ensure accuracy and to revise any of the information as necessary. Due to frequent turnover in offsite organizations, it is often necessary to update letters with the most current individual in charge while the content of the letter remains unchanged. The removal of the letters of the Emergency Plan will allow these types of changes to occur without requiring a revision to the entire Emergency Plan document for administrative updates. None of the letters have been revised as a result of this revision. Going forward, all of the letters will continue to be screened and evaluated under the 10CFR50.54(q) review process to ensure the effectiveness of the Emergency Plan is not reduced. The inclusion of a cross reference to the letters of agreement with offsite agencies for emergency response support and resources continues to comply with the requirements of 10CFR50.47(b)(3) and does not reduce the effectiveness of the Emergency Plan because all of the letters continue to be maintained as an extension of the Emergency Plan and all changes must be screened and evaluated under the 10CFR50.54(q) review process to ensure the effectiveness of the Emergency Plan is maintained at all times. This change can be implemented without prior NRC approval.

Appendix F "Evacuation Time Estimates" (ETE) has been revised to remove the summary of the evacuation time estimate and create a cross reference to the entire document that is completed by an outside agency. The ETE is completed by a contract agency and maintained in the Emergency Planning Department files. Copies of this study are provided to the States of VT, NH and MA for use in their planning efforts. The inclusion of a cross reference to this document will ensure that the ETE remain a part of the Emergency Plan while also eliminating the potential for errors by removing the summary document that was maintained separately from the original ETE study. The inclusion of a cross reference to the ETE study continues to comply with the requirements of 10CFR50.47(b)(10) and does not reduce the effectiveness of the Emergency Plan because an ETE remains available as an extension of the Emergency Plan detailing the population located in the plume exposure pathway for the emergency planning zone (EPZ) and copies of the ETE are provided to the State and local governmental authorities each time the study is performed. This change can be implemented without prior NRC approval.

The proposed changes to the Emergency Plan, continue to meet the requirements of 10 CFR 50.47(b)(1),

Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, 10 CFR 50.47(b)(3), Emergency Response Support and Resources, 10 CFR 50.47(b)(5), Emergency Notifications, 10 CFR 50.47(b)(6), Emergency Communications, 10 CFR 50.47(b)(8), Emergency Facilities and Equipment, 10 CFR 50.47(b)(10), Emergency Protective Actions and the effectiveness of the Emergency Plan is not reduced. These Emergency Plan changes can be implemented without prior NRC approval.

EN-EP-305 REV 3

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Answer the following questions about.the proposed-change..,.

1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? OYES 0 NO I IEOI 2.. Dcoe the propesed-change maintain theeffectivenessoDt the* emergenrcy pan (I0e., no ri.* 'a 1 61 ll e. ; e- -a--".

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Ifquestions I or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR i ukNW it. L10~2 id NNW fo R process(es). Refer to step-568raj. . , ,, *@= ui!. r*. I'. impiemeni app.cao[1e cnange vui~ vi. 1u1uaures Preparer Name (Print) Preparer Signature Date:

Justine Anderson L dV, 12/2/13 (Optional) Reviewer Name (Print) Reviewer Signature Date:

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Reviewer Name (Print) ' gDate:.

Tom Sowdon Nudear EP Project Manager Approver Name (Print) Approver Signature Date:

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EN-EP-305 REV 3

EMERGENCY PLAN ENTERGY VERMONT YANKEE VERNON, VERMONT REVISION 54

.PREPARER:

Ernergency Pinfirft Man e PrlnUSign) f " Date REVIEWED:

Vincent airacara 1~l./7 APPROVED:

Goneral Manager P nS* n) Date APPROVED:

Site VIcb Preelded t PrIntSIgn) ai Effective Date 12/19/13

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.

03/15/05 40 Removed references to satellite phones. Revised Figures 7.1 and 7.2.

Updated Evacuation Time Estimate (Appendix F) based on study conducted in 2004. Updated Table 4.2 and Figures 4.3, 4.4 and 4.5 based on 2000 census data per UFSAR Rev. 19. Updated Section 4.2 for latest population figures per UFSAR Rev. 19. Joint News Center activation changed from SAE to Alert. Removed references to "typically filled by" titles and "designated alternates" due to change-to four teams. Deleted Table 8.1. Changed alternate Joint News Center location from Marlborough, MA to Landmark College. Revised Figure 6.3 for new OSC Communication Center location. Revised Figure 6.4 for new EOF/RC Center Layout. Section 8.2.1 SRM responsibilities revised. Section 8.2.2 TSC Coordinator responsibilities revised. Security Coordinator position reports to off site command center instead of the TSC. Revised Figure 8.3.

Removed requirement for TS Coordinator to appoint an OSC Coordinator due to four team assignments. Revised Section 9.0 to require activation of the Joint News Center at the Alert. Revised Table 9.1. Updated Appendix E with recent letters of agreement from DOE/REAC and INPO. Deleted letters of agreement with Duke Engineering & Services for old alternate joint news center and Yankee Rowe for lab sample analysis and decontamination services. Updated Appendix G with new procedures AP 3549 and OP 3550. Removed reference to JNC Guidelines which were replaced by OP 3550.

Changed OP 3505 to AP 3505 and OP 3712 to AP 3712. Deleted Section 8.2.7 Radiological Coordinator. Section 8.2.6 revised Rad Assistant responsibilities. Revised Table 8.4 to remove reference to Radiological Coordinator. Revised Figure 8.2 to delete Radiological Coordinator. Revised Figure 8.5 to delete Radiological Coordinator and communicators. Replaced with Radio Operator and RP staff.

Revised Figure 8.7 to reflect changes due to four team rotation.

Emergency Plan Revision 54 Revision Summary Page i of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 01/18/06 41 Incorporated changes per NRC Bulletin 2005-02 (ECL definition changes, Security drills, Hostile Action definitions). Changed "Unusual Event" to "Notification of Unusual Event" to conform to industry standards. Changed title - Director of Public Affairs to Manager of Communications. Changed reference from Plant Operations Review Committee to On-Site Safety Review Committee. Letters of agreement reviewed annually in conjunction with annual review of the E-Plan. Updated respiratory protection locations per RP changes.

Updated letters of agreement for States, DOE-REAC/TS and Vernon Fire Department. Added letters of agreement for States regarding Alert & Notification System (ANS). Added OP 3548 and OP 3551 to list of Implementing Procedures in Appendix G. Updated Appendix H for the implementation of the new siren system.

06/22/06 42 Corrected Hostile Force definition - "overtly" had been omitted from the last revision (WT-VTY-2006-00000 CA#00463). Revised thermal rated power per License Amendment #229, issued March 2, 2006 (CR-VTYLO-2006-0004 CA#23). Removed reference to gross electrical output. Per Regulatory Information Summary 2003-18, Supplement 2, issued December 12, 2005, removed the requirement for states to concur with changes to the Emergency Action Levels.

Changed TLD (thermoluminescent device) references to DLR (dosimeter of legal record) per Radiation Protection change. Replaced the annual INPO letter of agreement with the latest version. Updated the general letters of agreement with Vermont and New Hampshire.

Added memorandum of understanding for Alert & Notification System with Vermont and New Hampshire. Added new procedure, OP 3552, Activation and Operation of the Alternate Joint News Center.

Emergency Plan Revision 54 Revision Summary Page ii of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 10/10/07 43 Changed TLD (thermoluminescent device) references to DLR (dosimeter of legal record) per Radiation Protection change. Replaced the annual INPO letter with the latest version. Updated the general letters of agreement with Franklin Medical Center, Brattleboro Memorial Hospital, Rescue, Inc. Ambulance Service, Vernon Fire Department, Brattleboro Fire Department, Vermont Yankee Nuclear Power Corporation. Appendix G - added new procedures, AP 3553, Administration and Maintenance of the Alert and Notification System, and AP 3554, Emergency Plan Teams; deleted references to procedures OP 3524, OP 3525 and OP 3531 which were incorporated into other procedures; added EN-EP-605, Corporate Incident Response Team. Changed Joint News Center to Joint Information Center throughout. Changed Figure 6.1 to reflect new location of Massachusetts Region III EOC. Revised Figure 6.3 to remove reference to the medical office and update Control Point personnel contamination monitor label. Changed reference from Vermont Operational Quality Assurance Manual to Entergy Quality Assurance Manual. Removed references to the Duty On Call Officer. Removed requirement for Plant Certification for the TSC Coordinator. Changed references to "corporate-level" to reflect Entergy organization.

Revised EOF Coordinator and Radiological Assistant responsibilities to reflect organizational changes. Changed "onsite assistance teams" to "repair and corrective action teams." Revised Figure 8.5 to indicate that the EOF Coordinator is not needed for activation of the EOF.

Removed references that required the TSC Coordinator to respond at the Notification of Unusual Event level and revised the responsibility to direct and coordinate all emergency response efforts. Revised Table 9.1 to reflect changes in the emergency response organization structure. Removed respiratory protection from the equipment inventory for the EOF. Revised "Emergency Broadcast Stations" to "Emergency Alert System stations." Removed reference to the Engineering Support Group as a separate entity. The Engineering Support Group is part of the TSC. Fire Brigade Leader changed from Shift Technical Advisor to Field Support Supervisor on Table 8.4.

Removed specific number of federal agencies available. Revised the reference to the TSC capacity. Revised the OSC Coordinator location to direct the OSC. Removed "designee" to the SRM responsibility to approve press releases. Removed switchboard from the EOF.

Removed NID Assistant from the JIC. Revised Table 9.1 to reflect ERO structure. Added the use of State Reception Center for decontamination efforts.

Emergency Plan Revision 54 Revision Summary Page iii of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 02/06/08 44 Implementation of the Independent Spent Fuel Storage Installation (ISFSI). Include ISFSI Emergency Action Level (EAL) for Notification of Unusual Event. Include definitions for ISFSI and Confinement Boundary. Update sections, tables and figures for title changes due to fleet alignment. Facility activation procedures incorporated into facility operation procedures.

08/21/08 45 Implementation of the fleet standard Emergency Response Organization (ERO). Joint Information Center relocation.

03/12/09 46 Reference to Federal Radiological Emergency Response Plan (FRERP) changed to National Response Framework (NRF). Editorial changes. Rearrange OSC and EOF layouts. Annual Update of Letters of Agreement - no content change. Additional sirens added to Appendix H. Add FVY reference numbers to letters cited in Table 8.4 Note 1.

12/15/09 47 Revised Section 5.0 to indicate that the revised Emergency Action Levels are based on NUMARC/NESP-007 (NEI 99-01), "Methodology for Development of Emergency Action Levels", Rev. 5, dated February 2008. Revised 6.2.3, Meteorological Capability, to reflect the as-built elevations for the temperature instruments. Deleted reference to the UHF radio antennas being mounted on the primary meteorological tower in Section 7.3. Changed "Federal Radiological Emergency Response Plan" to "National Response Framework" on Figure 9.1.

Revised paragraph 5 of Section 12.1.2, Communications Tests, to indicate the monthly NRC communications test is with the Headquarters Operations Officer rather than the NRC Region I Office.

Replaced the AP 3125 EAL Chart with the revised EAL charts in Appendix A. Replaced AP 3505, Emergency Preparedness Exercises and Drills, with fleet procedures EN-EP-306, Drills and Exercises, and EN-EP-307, Threat Based Drills, in Appendix G. Corrected siren numbers on the Siren List in Appendix H. Added the siren drawing for the Bernardston sirens in Appendix H.

03/30/10 48 Revised Figure 4.1 to add the Vernon Substation.

10/21/10 49 Revised Table 8.4: Added STA (1) to Plant Operations & Assessment of Operational Aspects functional area section. This change is being instituted to clarify specific coverage detail. Deleted the verbiage that specifies who the fire brigade consists of (FSS, 3 AO, and 1 Security) from the Fire Fighting functional area section. Added an (*)with comment that "Position staffed in accordance with Technical Requirements Manual and administrative procedures". The change is being instituted to be consistent with the TRM and to simplify upkeep of the Emergency Plan document.

Emergency Plan Revision 54 Revision Summary Page iv of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 04/28/11 50 Updated figure 6.4 to reflect changes in the EOF facility arrangement.

Updated section 6.2.6, 10.1.3, 10.3, Appendix B and Appendix D to reflect current capabilities for outside analytical assistance and laboratory facilities support. Updated letters of agreement for: State of Massachusetts, State of New Hampshire, State of Vermont, Vernon Fire Department, Brattleboro Fire Department, and Institute of Nuclear Power Operations. Updated memorandum of understanding for State of Massachusetts Alert & Notification System, State of New Hampshire Alert & Notification System, and State of Vermont Alert & Notification System.

Emergency Plan Revision 54 Revision Summary Page v of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

Section 3.2: Actions In an Emergency, Step 7 5/24/12 51 Step 7 was revised from "Use the plant pager system to notify appropriate personnel..." to "use the emergency notification system to notify appropriate personnel..."

Section 6.1.3: Emergency Operations FacilltylRecovery Center Added a statement to address ERO Augmentation at Alternate Facilities Section 8.4.1, Local Service An editorial change was made to this section to add Baystate to the name of Franklin Medical Center Table 8.4, Minimum Staffing Requirements for the ENVY ERO Table 8.4 has been updated to replace Security with the Fire Brigade for the functional area of "Rescue Operations & First Aid", Changed Rad Waste Operator from ACRO to CRO Section 9.1 Emergency Condition Recognition and Classification Added a statement to address Emergency Declaration Timeliness Section 9.2.4 General Emergency Response, Step 1 This section was updated to refer to the Corporate Emergency Center located in Jackson MS for the EOF Manager to contact in a General Emergency for fleet support.

Figure 9.1, Notification Plan Figure 9.1 notification plan has been updated to align with the implementation of Everbridge and OP 3540, (Control Room Actions During an Emergency) and show operations as the initiator of the notifications Section 10.4.4, Use of Onsite Protective Equipment and Supplies Editorial change to correct Iodine to Iodide.

Section 10.6, Protective Actions for Onsite Personnel Added a statement for Protective Actions for Onsite Personnel Section 12.1.2, Communication Tests Section 12.1.2 has been updated to align with the Everbridge implementation at Vermont Yankee and revise the wording for the weekly communication test.

Appendix E - Letters of Agreement Updated the following letters (18 is newly added) o Letter 4, Baystate Franklin Medical Center o Letter 5, National Weather Service (NOAA) o Letter 6, Brattleboro Memorial Hospital o Letter 7, Rescue Inc Ambulance Service o Letter 10, Institute of Nuclear Power Operations o Letter 11, Town of Vernon o Letter 12, DOE o Letter 13, DOE-REAC/TS o Letter 14, Vermont Yankee Nuclear Power Corporation o Letter 18, Landmark College Appendix G - Index of Emergency Plan Implementing Procedures and Support Plans o Emergency Plan Implementing Procedures o Support Plans o Corporate Support Procedures Emergency Plan Revision 54 Revision Summary Page vi of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

Section 7.9 "Emergency Response Data System" Removed 12/20/12 52 wording regarding activation within one hour of an alert and replaced it with a statement for maintaining a continuous connection Section 8.1 "Normal Plant Organization" Updated the on shift staffing to include one (1) FSS, five (5) AOs, and one (1) Utility employee per the Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis Section 8.2.3 "Shift Manager" Updated the last sentence of the paragraph to state "The immediate responsibilities of the Shift Manager include performing or delegating performance of the following."

Table 8.4 "Minimum Staffing Requirements for the ENVY ERO"

• Replaced SCRO with CRS in the Table and on note 4. Title change only.

• Updated AOs from 3 to 5

• Added 1 FSS

" Added FSS to offsite dose assessment

• Note 1: Added a reference to the Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis for composition of the 5 person fire brigade

• Note 4: Added FSS for performing initial dose assessment Appendix A "Emergency Classification System and Emergency Action Levels" - Added a cross reference to AP 3125, "Emergency Plan Classification and Action Level Scheme" for EAL Charts and removed the image of the EAL Chart Appendix G "Index of Emergency Plan Implementing Procedures and Support Plans"

• II. Support Plans - Added Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis

• Corporate Support Plans: Added procedure EN-EP-302 "Severe Weather Response" effective 11/5/12 Emergency Plan Revision 54 Revision Summary Page vii of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued)

Section 8.1, Normal Plant Organization 9/17/13 53 9 Updated AOs from 5 to 6

• Deleted Utility person Table 8.4, Minimum Staffing Requirements for the ENVY ERO

" Plant Operations & Assessment of Operational Aspects -

Updated AOs from 5 to 6

• Fire Fighting - Added the total number (5); Added ** to reference the note "May be provided by shift personnel assigned other functions" and added reference to note 1 regarding the Fire Brigade being staffed lAW TRM, Staffing Analysis and AP 0894.

Figure 8.1 - Corrected the number on on shift AOs and added the Field Support Supervisor (FSS)

Appendix E, Letters of Agreement

• Updated INPO letter for 2012

" DOE - REAC/TS - Updated letter dated June 6, 2013. The letter content remains unchanged.

" Deleted letter 14 "Vermont Yankee Nuclear Power Corporation" no longer valid as of 12/31/12 Appendix G, Index of Emergency Plan Implementing Procedures and Support Plans

• Added Fleet Administrative Procedure references

• Updated procedure references in accordance with the procedure upgrade project numbering scheme Emergency Plan Revision 54 Revision Summary Page viii of ix Entergy Vermont Yankee

REVISION

SUMMARY

(Continued) 12/19/13 54 nL

• Added 7.1 InForm Notification System 3.2. Actions in an Emergencv

• Changed Nuclear Alert System to Emergency Notification System in step 5 for notifying the three states 6.2.6. Facilities and Eauioment for Offsite Monitorina 0 Removed the reference to the James A. Fitzpatrick environmental laboratory 7.1. InForm Notification System

• Added a description for the InForm Notification System 7,*. Nuclear Alert System

• Changed the words "is used" to "can be" used to describe the Nuclear Alert System Figure 7.1. Plant to State Notification Channels

• Added a line for Inform Figure 7.2. Coordination Channels with States

• Added a line for Inform Section 8.1. Normal Plant Organization 0 Removed the Field Support Supervisor from the Normal Plant Organization Table 8.4. Minimum Staffing Requirements for the ENVY ERO

" Notification/Communication: changed Chem Tech to AO

• Radiological Accident Assessment - Deleted Field Support Supervisor (FSS) and added Chem Tech.

" Note 4 - Deleted FSS and added Chem Tech Fiaure 8.1. Normal On-Shift Emergency Ormanization

• Revised to match shift staffing in section 8.1 and remove the Field Support Supervisor (FSS)

Figure 9.1. Notification Plan

• Changed NAS to Inform/NAS Appendix E. Letters of Agreement

• Letters of Agreement have been removed from this document and will be maintained in the Emergency Plan Department files. A summary of the agreements has also been added.

Appendix F. Evacuation Time Estimates

• An evacuation time estimate summary has been removed from this document and the entire document is maintained separately and referenced in this appendix.

Apoendix G, Index of Emergency Plan Imolementing Procedures and Support Plans

• Updated procedure numbers to match the procedure upgrade project numbering

• Added the Evacuation Time Estimate to Support Plans Emergency Plan Revision 54 Revision Summary Page ix of ix Entergy Vermont Yankee

TABLE OF CONTENTS

1.0 INTRODUCTION

........................................................................................................ 1 2.0 DEFINITIONS ..................................................................................................... 2 3.0 SUM MARY OF EM ERGENCY PLAN ................................................................... 6 3.1. Objectives ................................................................................................... 6 3.2. Actions In An Emergency .................................. 7 3.3. Emergency Response Facilities .................................................................. 7 3.4. Mobilization ................................................................................................. 8 3.5. State Government Notification and Response ............................................ 8 3.6. Federal Government Notification and Response ....................................... 9 3.7. Technical Support ....................................................................................... 9 4.0 THE AREA .......................................................................................................... 10 4.1. The Site ..................................................................................................... 10 4.2. Area Characteristics, Land Use and Demography .................................... 10 4.3. Emergency Planning Zones ....................................................................... 11 5.0 EMERGENCY CLASSIFICATION SYSTEM ...................................................... 24 5.1. Notification of Unusual Event .................................................................... 24 5.1.1. Unusual Event (Term inated) ...................................................... 25 5.2. Alert .......................................................................................................... 25 5.3. Site Area Emergency ................................................................................ 25 5.4. General Emergency .................................................................................. 26 5.5. Emergency Classification System Review by State Authorities ................. 26 6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT ............................. 27 6.1. Emergency Response Facilities ................................................................ 27 6.1.1. Technical Support Center ........................................................ 27 6.1.2. The Operations Support Center ............................................... 28 6.1.3. Emergency Operations Facility/Recovery Center ..................... 29 6.1.4. Deleted .................................................................................... 30 6.1.5. Joint Inform ation Center .......................................................... 30 6.1.6. Coordination of Radiological Data ............................................ 30 6.2. Assessment Capability .............................................................................. 31 6.2.1. Process Monitors ...................................................................... 31 6.2.2. Radiological Monitors ............................................................... 31 6.2.3. Meteorological Capability ........................................................... 32 6.2.4. Fire Detection Devices ............................................................. 33 6.2.5. Post-Accident Sampling ............................................................. 33 6.2.6. Facilities and Equipment for Offsite Monitoring .......................... 33 7.0 COMM UNICATIONS ............................................................................................ 39 7.1. InForm Notification System ...................................................................... 39 Emergency Plan Revision 54 Table of Contents Page i of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued) 7.2. Nuclear Alert System ................................................................................ 39 7.3. Utility Microwave and Radio Systems ...................................................... 40 7.4. Mobile UHF Radio System ....................................................................... 40 7.5. Plant Intercom System ............................................................................. .40 7.6. NRC Telephone System ............................................................................ 40 7.7. Commercial Telephone System ............................................................... 41 7.8. Emergency Power Supply for Communications ....................................... 41 7.9. Facsimile Transmission .......................................................................... 41 7.10. Emergency Response Data System...................................................... 42 8.0 ORGANIZATION ................................................................................................. 46 8.1. Normal Plant Organization ...................................................................... 46 8.2. Emergency Response Organization ........................................................ 46 8.2.1. Emergency Director .................................... ......... 48 8.2.2. Emergency Plant Manager ....................................................... 49 8.2.3. Shift Manager .......................................................................... 50 8.2.4. EOF Manager ........................................................................... 51 8.2.5. Operations Support Center Manager ........... ;............................ 52 8.2.6. Radiological Assessment Coordinator ...................................... 53 8.2.7. Administration and Logistics Coordinator ................................. 54 8.2.8. Security Coordinator .................................................................. 54 8.2.9. Company Spokesperson .......................................................... 554 8.2.10. Decision Maker...................................... 55 8.2.11. Engineering Support Group ........................................................ 55 8.3. Recovery Organization .............................................................................. 56, 8.4. Extensions of Vermont Yankee Emergency Organization ............ 57 8.4.1. Local Service ............................................................................ 57 8.4.2. Federal Government Support .................................................. 57 8.4.3. Additional Support .................................................................... 58 8.5. Coordination with, State Government Authorities ...................................... 58 9.0 EMERGENCY RESPONSE .................................................... 70 9.1. Emergency Condition Recognition and Classification ..... .................. 70 9.2. Activation of the Emergency Organization ................................................ 70 9.2.1.' Notification of Unusual Event Response ................................... 71 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 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 C apability ................................................................................ . . 79 Emergency Plan Revision 54 Table of Contents Page ii of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued) 10.1.3. Evaluation of Offsite Air Samples ............................................. 80 10.2. Protective Action Recommendation Criteria ............................................. 81 10.3. Radiological Exposure Control .................................................................. 81 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 10.6. Protective Actions for Onsite Personnel .................................................... 84 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION ........................... 92 11.1. Emergency Notification .............................................................................. 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. Security Drills ........................................................................... 97 12.1.8. Scenarios ................................................................................... 97 12.1.9. Evaluation of Exercises ............................................................ 98 12.1.10. 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 54 Table of Contents Page iii of vii Entergy Vermont Yankee

TABLE OF CONTENTS (Continued)

APPENDICES Page APPENDIX A Emergency Classification System and Emergency Action Levels 101 APPENDIX B Emergency Equipment 102 APPENDIX C Initial Offsite Dose Rate Estimation 105 APPENDIX D Environmental Laboratory Analytical- and Dosimetry Services 107 APPENDIX E Letters of Agreement 109 APPENDIX F Evacuation Time Estimates 111 APPENDIX G Index of Emergency Plan Implementing Procedures and Support Plans 112 APPENDIX H Public Notification System 115 Emergency Plan Revision 54 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 2000 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 (Deleted)

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 54 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 2000 Population Distribution Within 0-5 Miles of Vermont Yankee Figure 4.4 2000 Population Distribution Within 0-10 Miles of Vermont Yankee Figure 4.5 2000 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 Figure 8.3 Technical Support Center Emergency Organization Figure 8.4 Operations Support Center Emergency Organization Figure 8.5 Emergency Operations Facility Organization Figure 8.6 (Deleted)

Figure 8.7 Joint Information Center Organization Emergency Plan Revision 54 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 54 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 ifthe need arises. In addition, federal agencies have specified their nuclear power plant emergency response roles and capabilities in the National Response Framework (January 2008).

The objective of this document is to outline the overall response of the Company to an emergency at the site. Ifan 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.

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

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 Notification 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.

Confinement Boundary - The barrier(s) between areas containing radioactive substances and the environment.

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.

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

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

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

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

Emeraencv Operating Procedures - The outline of specific corrective actions to be taken by plant operators in response to abnormal operating conditions.

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

Emeraency 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.

Enaineerina SuDport 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 Emeraencv - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

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

Hostile Action - An act toward an NPP or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP.

Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area).

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

Independent Spent Fuel Storage Installation (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

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

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Joint Information 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 Company Spokesperson.

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

Operations Support Center - An emergency center established for available skilled emergency personnel (i.e., additional operations and support personnel). The Operations Support Center Manager 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.

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

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 Emergency Director 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 Emergency - Events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE Emergency Plan Revision 54 Page 4 of 125 Entergy Vermont Yankee

ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

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 Emergency Plant Manager 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 (Terminated) - A condition that warrants a Notification of 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.

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3.0

SUMMARY

OF EMERGENCY PLAN 3.1. Objectives 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.

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Emergencies at nuclear power plants are classified into the following four major categories (as set forth in Section 5.0): Notification of 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 Ifan emergency condition develops, the Shift Manager, or the senior licensed individual in the Control Room, assumes the responsibilities 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 Emergency Notification System;

6) Notify the NRC using the Emergency Notification System;

7) Use the emergency notification 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 Information Center; and

9) Direct and coordinate all emergency response efforts until overall responsibility is assumed by the Emergency Director.

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 utilized. 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 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 Information Center provides the opportunity for joint utility, state and federal press briefings to be held.

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3.6. Federal Government Notification 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 National Response Framework (NRF). The NRF makes available the resources and capabilities of 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 1912 MWt. The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Entergy, 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 DemocaraDhy 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 site 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 from 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 2000 was estimated to be 126 people per square mile. Figures 4.3, 4.4, and 4.5 provide the 2000 population distribution within a 5-, 10-, and 50-mile radius of the Vermont Yankee Nuclear Power Station. Table 4.2 summarizes these data.

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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 "0"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 implemented in this area to the extent dictated by the release conditions.

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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 54 Page 13 of 125 Entergy Vermont Yankee

TABLE 4.2 2000 POPULATION DISTRIBUTION WITHIN THE 50-MILE EPZ OF VERMONT YANKEE POPULATION TOTALS BY ZONE Ring Cumulative Miles Population Miles Population 0-1 489 0-1 489 1-2 2496 0-2 2985 2-3 1937 0-3 4922 3-4 1556 0-4 6478 4-5 3441 0-5 9919 5-10 23954 0-10 33873 10-20 111005 0-20 144878 20-30 133847 0-30 278725 30-40 337525 0-40 616250 40-50 851123 0-50 1467373 POPULATION TOTALS BY SECTOR Total Population Total Population Sector 0-50 Miles Sector 0-50 Miles A (N) 46204 J (S) 458553 B (NNE) 36424 K (SSW) 120057 C (NE) 45230 L (SW) 32609 D (ENE) 50939 M (WSW) 78287 E (E) 92389 N (W) 44288 F (ESE) 188701 P (WNW) 31855 G (SE) 141941 Q (NW) 17512 H (SSE) 60442 R (NNW) 21912 Emergency Plan Revision 54 Page 14 of 125 Entergy Vermont Yankee

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

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

2. Dummerston, VT R and 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, and F (9-10) WSW-WNW

4. Swanzey, NH C (8-10), D (9-10) 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 F 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 54 Page 15 of 125 Entergy Vermont Yankee

Vermont Yankee Nuclear Power Station VImfno Elementary School Govcwnar -,

Hunt House a

N V'mwn Hydwostaiion nQ_-.20f ,inn A TRUE *v NOVRTt METERS Figure 4.1 Vermont Yankee Site Emergency Plan Revision 54 Page 16 of 125 Entergy Vermont Yankee

Figure 4.2 Population Center and Special Interest Areas Within the 50 Mile EPZ Emergency Plan Revision 54 Page 17 of 125 Entergy Vermont Yankee

N ENE WNW (D)

(P)

E W

i (E)

(N) 76 ESE WM) (F)

WSW (J) S Figure 4.3 2000 Population Distribution Within 0 - 5 Miles of Vermont Yankee Emergency Plan Revision 54 Page 18 of 125 Entergy Vermont Yankee

N (A)

ENE WNW (D)

(P)

E W

(E)

(N)

,ESE (F)

(M)

WSW SSW Figure 4.4 2000 Population Distribution Within 0 - 10 Miles of Vermont Yankee Emergency Plan Revision 54 Page 19 of 125 Entergy Vermont Yankee

N (A) NNE ENE WNW (P) (D)

E w

9858 (N) 5C ESE (M) (F)

WSW (J) S Figure 4.5 2000 Population Distribution Within 10 - 50 Miles of Vermont Yankee Emergency Plan Revision 54 Page 20 of 125 Entergy Vermont Yankee

3483140 N 11 1/4° NOTE: Each sector is 22° 2

• 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 54 Page 21 of 125 Entergy Vermont Yankee

0 5 10 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 54 Page 22 of 125 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 54 Page 23 of 125 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: Notification of 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 and EAL bases were derived from example initiating conditions in NUMARC/NESP-007 (NEI 99-01), "Methodology for Development of Emergency Action Levels", Rev. 5, dated February 2008. The EALs and bases have been modified in accordance with Letter USNRC to VYNPS, 'Vermont Yankee Nuclear Power Station -

Safety Evaluation for Emergency Action Levels (TAC No. MD9157)", dated June 16, 2009.

5.1. Notification of Unusual Event EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANT OR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HAS BEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED UNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.

Notification of Unusual Event conditions do not cause serious damage to the plant and may not require a change in operational status. The purpose of the Notification of 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 a Notification of Unusual Event.

Emergency Plan Revision 54 Page 24 of 125 Entergy Vermont Yankee

5.1.1. Unusual Event (Terminated)

Ifa condition that warrants a Notification of Unusual Event declaration has occurred, and was immediately rectified such that the condition no longer existed by the time of declaration, this Notification of 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.

5.2. Alert EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANT OR A SECURITY EVENT THAT INVOLVES PROBABLE LIFE THREATENING RISK TO SITE PERSONNEL OR DAMAGE TO SITE EQUIPMENT BECAUSE OF HOSTILE ACTION. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS.

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.

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

5.3. Site Area Emergency EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR LIKELY MAJOR FAILURES OF PLANT FUNCTIONS NEEDED FOR PROTECTION OF THE PUBLIC OR HOSTILE ACTION THAT RESULTS IN INTENTIONAL DAMAGE OR MALICIOUS ACTS; (1)

TOWARD SITE PERSONNEL OR EQUIPMENT THAT COULD LEAD TO THE LIKELY FAILURE OF OR; (2) THAT PREVENT EFFECTIVE ACCESS TO EQUIPMENT NEEDED FOR THE PROTECTION OF THE PUBLIC. ANY RELEASES ARE NOT EXPECTED TO RESULT IN EXPOSURE LEVELS WHICH EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS BEYOND THE SITE BOUNDARY.

Emergency Plan Revision 54 Page 25 of 125 Entergy Vermont Yankee

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.

5.4. General Emergency EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE ACTUAL OR IMMINENT SUBSTANTIAL CORE DEGRADATION OR MELTING WITH POTENTIAL FOR LOSS OF CONTAINMENT INTEGRITY OR HOSTILE ACTION THAT RESULTS INAN ACTUAL LOSS OF PHYSICAL CONTROL OF THE FACILITY. RELEASES CAN BE REASONABLY EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS OFFSITE FOR MORE THAN THE IMMEDIATE SITE AREA.

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, is reviewed with the state authorities of Vermont, New Hampshire, and Massachusetts.

Emergency Plan Revision 54 Page 26 of 125 Entergy Vermont Yankee

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 Emergency Plant Manager 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.

Emergency Plan Revision 54 Page 27 of 125 Entergy Vermont Yankee

Upon activation, the TSC provides the main communication link between the plant, the Control Room, the NRC and the Emergency Operations Facility/Recovery Center. 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 Emergency Plant Manager 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 Emergency Plant Manager under a Notification of 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 radioiodine. 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 Emergency Director or the Emergency Plant Manager, 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 Manager directs the activities of this center. 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 Emergency Plant Manager.

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.

Emergency Plan Revision 54 Page 28 of 125 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.

(NVY 84-44, February 27, 1984) The EOF, with communication capabilities for contacting the Control Room and plant Security, is available to serve as a staging area for augmented emergency response staff ifthe site is under threat of or experiencing hostile action. The overall responsibility for the functions performed in the EOF/RC belongs to the Emergency Director.

The Emergency Director acts as the principal spokesperson for Vermont Yankee concerning all issues where an interface with offsite government authorities is required.

The Radiological Assessment 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 Information 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 sampling and analysis for airborne radioparticulates and radioiodine. For a list of EOF/RC emergency equipment, see Appendix B.

Emergency Plan Revision 54 Page 29 of 125 Entergy Vermont Yankee

6.1.4. Deleted 6.1.5. Joint Information Center The Joint Information Center (JIC) 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 JIC.

The initial designated location of the JIC is the Vermont Yankee Office Building located in Brattleboro, Vermont. Ifaccident conditions (plume trajectory) jeopardize the habitability of this facility, the alternate JIC at Landmark College in Putney, Vermont would be utilized.

At the JIC, the Company Spokesperson coordinates the generation and issuance of press releases concerning plant emergency conditions to the media. Prior to their release to the media, the Emergency Director approves releases.

The JIC will be activated upon an emergency classification of an Alert or higher except as noted below.

Activation of the JIC is optional prior to an Alert and is dependent on the escalation of the event and/or public interest. Prior to the activation of the JIC, the Manager of Communications 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 sample 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 HPGe or equivalent system. The EOF/RC sampling capability is greatly enhanced by coordinating sample transfer and analysis with the Environmental Laboratory.

Emergency Plan Revision 54 Page 30 of 125 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 54 Page 31 of 125 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 300-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,

• Ambient temperature at the 33 foot level, and

• Vertical temperature difference between the 33 and 198-foot levels and the 33 and 295 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 54 Page 32 of 125 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 the 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.

In addition to the analytical capabilities of the EOF, Vermont Yankee has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities through INPO. This support may include but is not limited to the following:

Massachusetts Department of Public Health (MDPH) through the implementation of the Nuclear Incident Advisory Team (NIAT) Handbook has laboratory analysis capability at the State Contracted laboratories and those laboratories listed in the New England Interstate Radiation Assistance Plan.

Emergency Plan Revision 54 Page 33 of 125 Entergy Vermont Yankee

Other environmental monitoring and analysis support can be requested and arranged through INPO. The INPO Emergency Resources Manual includes the information necessary to locate and request specialized equipment and technical assistance in the area of offsite radiological monitoring. INPO member utilities and suppliers agree to provide assistance as outlined in the INPO Emergency Resources Manual.

The above facilities have the capability to perform laboratory analyses of various environmental samples (e.g., terrestrial, marine and air). It is also estimated that the analytical assistance and laboratory support will be able to respond within four (4) to eight (8) hours from initial notification.

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 54 Page 34 of 125 Entergy Vermont Yankee

0 10 20 30 40 50 Miles Figure 6.1 Location of State and Company Emergency Operating Centers around Vermont Yankee Emergency Plan Revision 54 Page 35 of 125 Entergy Vermont Yankee

Figure 6.2 Technical Support Center Layout Emergency Plan Revision 54 Page 36 of 125 Entergy Vermont Yankee

U U CLEAN CHEMI J

// /I m CHEM LAB COUNTING RAITION *" ROOM PROTECTION OFFICES X COMMUNICATION OFFIC DECON SHOWERS CENTER LV""

-u E-PLAN EQUIPMENT -I LJJ PCM CLEAN SHOWER ROOM CONTROL POINT BRIEFING ROOM

-TI LOCKER ROOM r-_

I Im FIRE BRIGADE ROOM RAD PROT II AO ROOM Figure 6.3 Operations Support Center Layout Emergency Plan Revision 54 Page 37 of 125 Entergy Vermont Yankee

Figure 6.4 Emergency Operations FacilitylRecovery Center Layout I-STATE ASSEMBLY II RECOVERY OSMT PLANNING COMMUNICATION NRC ROOM AREA FIELD TEAM 9'k COORDINATION CHEMISTRY & (0 SAMPLE ANAL. C.)

LAB U)'

WOMENME DECON AREA Emergency Plan Revision 54 Page 38 of 125 Entergy Vermont Yankee

7.0 COMMUNICATIONS 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. InForm Notification System The InForm Notification System is located in the Control Room and the Emergency Operations Facility. InForm consists of source and destination computers that take advantage of the internet to send Emergency Notification Forms to the States of Vermont, New Hampshire and Massachusetts during a declared emergency.

This system is staffed 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. InForm performs self checks every 10 seconds.

Backup to the InForm Notification System is the Nuclear Alert System.

7.2. 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 can be 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 staffed 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).

Backup to the NAS phone system is the commercial phone system.

Emergency Plan Revision 54 Page 39 of 125 Entergy Vermont Yankee

7.3. 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 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.

7.4. Mobile UHF Radio System 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. These repeaters are activated by any of the six base radio stations located in the Control Room, Secondary Alarm System (SAS), TSC, Security Gate 1 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.

7.5. 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 I 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.

7.6. 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.

Emergency Plan Revision 54 Page 40 of 125 Entergy Vermont Yankee

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 EOF/RC.

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.

7.7. Commercial Telephone System 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.

7.8. Emerg-ency Power Supply 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 Information Center (JIC), and each respective state's Emergency Operation Center (EOC).

This is used to transmit pertinent data and information concerning the emergency among these facilities.

Emergency Plan Revision 54 Page 41 of 125 Entergy Vermont Yankee

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 maintains a continuous ERDS connection with the NRC Operations Center.

Emergency Plan Revision 54 Page 42 of 125 Entergy Vermont Yankee

TABLE 7.1 VERMONT YANKEE EMERGENCY COMMUNICATIONS MATRIX CALLING FROM CALLING TO CR TSC OSC EOF JIC Technical Support Center (TSC) 1,4,5,7 Operations Support Center (OSC) 1,7 1,7 -

Emergency Operations Facility (EOF) 1,2,4 1,4,10 1 Joint Information Center (JIC) 1 1,10 1 1,10 Offsite and Site Boundary Monitors 1,4 1,4 1 1,4 I Nuclear Regulatory Commission 1,5 1,5,6 1 1,5,6 1 State Police (VT, NH, MA) 1,2 1 1 1,2 1 State EOCs (VT, NH, MA) 1,2,9 1 1 1, 2,9,10 I Vermont Yankee Plant Security 1,4,7 1,4,7 1,7 1,4,7 I Vermont Yankee Emergency Response Personnel 1,8 1,8 1,8 1,8 1,8 W

KEY 1 Commercial Telephone System 2 Nuclear Alert System 3 Utility Microwave 4 Mobile UHF Radio System 5 Emergency Notification System 6 Health Physics Network 7 Gai-Tronics 8 Personnel Pager System 9 Southwest Fire Radio 10 Facsimile Transmission Emergency Plan Revision 54 Page 43 of 125 Entergy Vermont Yankee

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

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

Figure 7.1 Plant to State Notification Channels Emergency Plan Revision 54 Page 44 of 125 Entergy Vermont Yankee

NOTE:

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

2. SEE STATE RESPONSE PLAN FOR LOCALS AND OTHER* STATE AGENCIES .........

TO BE NOTIFIED.

• I I

j.:

3 UNLISTED TELE. NOS.C - .

1-EA STATE  : I

................. ... l... ..° .

................. "rS. ...

I

i E PRIMARY I '

SECONDARY * ... S O TERTIARY

• SlllBII~

,,-- LOCAL PHONE NUCLEAR ALERT SYSTEM

........ INFORM Figure 7.2 Coordination Channels with States Emergency Plan Revision 54 Page 45 of 125 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 Entergy 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, six (6) 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. Additional personnel are available on an on-call basis to respond to plant emergencies. Corrective action and 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 Shift Manager; 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 54 Page 46 of 125 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 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, Emergency Plant Manager, or OSC Manager 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 Emergency Plant Manager and OSC Manager 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.

Emergency Plan Revision 54 Page 47 of 125 Entergy Vermont Yankee

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

The Emergency Director's principal responsibilities are to:

1. Assume overall responsibility, from the Shift Manager for the response actions necessary for control of the accident and protection of emergency personnel and the public;

2. Assume responsibility from the Shift Manager for offsite States' notification; (non-delegable)

3. Assume responsibility, from the Shift Manager for authorization of escalation, and de-escalation of the emergency;

4. Assume responsibility, from the Shift Manager 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 Emergency Director or designated alternate is notified of all emergency conditions occurring at the plant. For Alert, Site Area Emergency and General Emergency conditions, the Emergency Director 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.

Emergency Plan Revision 54 Page 48 of 125 Entergy Vermont Yankee

8.2.2. Emergency Plant Manager The Emergency Plant Manager has direct responsibility for the conduct of operations at the plant. During an emergency situation, the Emergency Plant Manager 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 Emergency Plant Manager's primary responsibilities are to:

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

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

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

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

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

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

7. Provide assistance to the Shift Manager or Emergency Director on the escalation and de-escalation of the emergency classification as conditions warrant;

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

A qualified manager assumes the role of Emergency Plant Manager under all emergency conditions. To assist the Emergency Plant Manager, the TSC is staffed by representatives from the following departments as depicted in Figure 8.3:

• Operations

• Maintenance

• Reactor Engineering

• Engineering

• Chemistry (in the OSC)

• Radiation Protection

• Security (stationed at the off site command post)

Emergency Plan Revision 54 Page 49 of 125 Entergy Vermont Yankee

8.2.3. Shift Manager The Shift Manager 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 Shift Manager is responsible for initiating emergency actions to limit the consequences of the event and bring it under control. The immediate responsibilities of the Shift Manager include performing or delegating performance of the following:

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.

Subsequent responsibilities undertaken by the Shift Manager 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 Shift Manager 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.

Emergency Plan Revision 54 Page 50 of 125 Entergy Vermont Yankee

8.2.4. EOF Manager The EOF Manager is a designated staff member of Vermont Yankee management specifically trained to be responsible for the facility Emergency Plan with respect to operation of the EOF/RC. The EOF Manager's primary responsibilities are to:

1. Establish the Emergency Operations Facility when required;

2. Assess Emergency Operations Facility habitability via the Radiological Assessment Coordinator;

3. 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 Manager at an Alert or higher emergency classification.

The EOF Manager is responsible for reporting to the Emergency Director.

Emergency Plan Revision 54 Page 51 of 125 Entergy Vermont Yankee

8.2.5. Operations Support Center Manager A member of the plant staff is assigned to coordinate the functions of the Operations Support Center. The responsibilities of the Operations Support Center Manager include:

1. Provide system valve alignment and equipment operation support to the Shift Manager;

2. Assist in coordinating recovery efforts as requested by the Emergency Plant Manager;

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. Repair and Corrective Action/Rescue Team

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

The OSC Manager directs the OSC and maintains this facility until the termination of the event. The OSC Manager 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 54 Page 52 of 125 Entergy Vermont Yankee

8.2.6. Radiological Assessment Coordinator During emergency conditions, the Radiological Assessment Coordinator 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 primary emergency responsibilities of the Radiological Assessment Coordinator include:

1. Assess the onsite and offsite radiological conditions associated with any accidental releases.

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

3. Provide support to the TSC to ensure onsite protective action recommendations (i.e., decontamination procedures, protective clothing, etc.)

are being considered and carried out;

4. Continuously update the Emergency Director concerning dose assessment results and recommend offsite radiological protective actions to the Emergency Director;

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.

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

8. Receive and document all sample results;

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

The immediate priority of the Radiological Assessment 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 Assessment Coordinator works closely with the services provided by support organizations (e.g.,

Environmental Lab).

Emergency Plan Revision 54 Page 53 of 125 Entergy Vermont Yankee

8.2.7. Administration and Logistics Coordinator The Administration and Logistics Coordinator is authorized to provide administrative, logistic and communication services for the emergency organization at the site.

Specifically, the responsibilities of the Administration and Logistics Coordinator include:

1. Function as an aid to the Emergency Director;

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 Emergency Director.

The Administration and Logistics Coordinator establishes operations at the EOF/RC and assists the Emergency Director, as requested.

8.2.8. Security Coordinator The Security Coordinator 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 Shift Manager;

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 Emergency Plant Manager for in-plant security actions. The Security Coordinator is stationed at the off-site command post.

Emergency Plan Revision 54 Page 54 of 125 Entergy Vermont Yankee

8.2.9. Company Spokesperson The Company Spokesperson is authorized to provide the public with information concerning the emergency. The emergency responsibilities of the Company Spokesperson include:

1. Establish a Joint Information Center when necessary;

2. Coordinate information at the Joint Information 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 Company Spokesperson reports to the Emergency Director.

The Manager of Communications or a designated alternate fills the position of the Company Spokesperson.

8.2.10. 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.

8.2.11. 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 resides in the Technical Support Center, and communicates with offsite technical support personnel. This group has access to the technical expertise to provide a variety of emergency functions, such as engineering analyses and plant system assessment in support of recovery efforts.

Emergency Plan Revision 54 Page 55 of 125 Entergy Vermont Yankee

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 affords 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 Emergency Director 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;

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 Emergency Director 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.

Emergency Plan Revision 54 Page 56 of 125 Entergy Vermont Yankee

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 Baystate 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, and the Annual Law Enforcement Letters of Agreement (Safeguards Information) maintained by Security.

8.4.2. Federal Government Support Resources of federal agencies appropriate to an emergency condition are made available in accordance with the National Response Framework. 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 54 Page 57 of 125 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 or greater emergency condition. The decision to request additional industry support is a responsibility of the Emergency Director. All industry support organizations reporting to the site are assigned by emergency management, located in the EOF/RC, who specifies 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 Shift Manager initiates the coordination effort by notifying Vermont, New Hampshire and Massachusetts State Police, providing them with an established message format that describes 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 Emergency Director 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 Emergency Director can authorize dispatching of technical support staff to assist them in comprehension of any emergency communications.

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 54 Page 58 of 125 Entergy Vermont Yankee

0 0 0 TABLE 8.3 (Page I of 3)

A

SUMMARY

OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION PLANT RESPONSIBILITY STATE RESPONSIBILITY LOCAL RESPONSIBILITY Protective Action Decision The Shift Manager issues the initial State Police receive the initial The State Directors of Making protective action recommendation. notification whereupon they activate Emergency Management the State fan-out notification process. Agencies will notify either the local emergency management directors or the selectmen of the recommended action and advise.

After the Emergency Director (ED) In the State of Vermont, the Director assumes overall responsibility, the of the Vermont Emergency ED will issue protective action Management Agency and the Director recommendations to the appropriate of the Division of Occupational Health State authorities (non-delegable). and 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.

Emergency Plan Revision 54 Page 59 of 125 Entergy Vermont Yankee

0 TABLE 8.3 (Continued)

(Page 2 of 3)

A

SUMMARY

OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION PLANT RESPONSIBILITY STATE RESPONSIBILITY LOCAL RESPONSIBILITY Protective Action Decision Each State Health representative Making (continued) would call or report to the plant for the follow-up protective action recommendation issued by the Emergency Director.

Each State Health representative will 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 Assessment Each State Health representative at Local communities rely on Coordinator is responsible for the EOF/RC will request monitoring State capability for radiological compiling offsite monitoring results updates from the EOF Manager. evaluation.

and for ensuring an effective deployment of monitoring personnel In the State of Vermont, the Director of as well as coordinating information the Division of Occupational &

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

Emergency Plan Revision 54 Page 60 of 125 Entergy Vermont Yankee

TABLE 8.3 (Continued)

(Page 3 of 3)

A

SUMMARY

OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION PLANT RESPONSIBILITY STATE RESPONSIBILITY LOCAL RESPONSIBILITY Coordination of Radiological Data The Emergency Director will advise In the Commonwealth of (continued) the State response personnel of Massachusetts, the Director of the results. Radiation Control Branch of the Massachusetts Department of Public Health will command this function at the State EOC.

In the State of New Hampshire, the 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 Agencies.

necessary.

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

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

Public Information Release The Emergency Director issues final State press personnel report to the Media inquiries are referred to approval prior to release. Joint Information Center. the Joint Information Center.

The Public Information Liaison at State press personnel coordinate the EOF/RC relays accident status releases with the Company reports to the Joint Information Spokesperson.

Center.

The Company Spokesperson releases the information to the media.

Emergency Plan Revision 54 Page 61 of 125 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 CRS (1) On Shift Operational Aspects CRO (2) On Shift AO (6) On Shift STA (1) On Shift Emergency Direction Shift Manager (1"*) On Shift

& Control (Emergency Coordinator)***

Notification / Notify Licensee, State STA/ AO On Shift Communication**"* local and federal STA/Offsite Comm/ENS Comm/Chem.Tech 30 min.

personnel & maintain (1)3 60 min.

communication STANOffsite Comm/ENS Comm/Chem.Tech (2)3 Radiological Emergency Operations EOF Emergency Director (1) 60 min.

Accident Facility (EOF) Director Shift Mgr/CRSISTA/Chem Tech On Shift Assessment and Offsite Dose assessment RP Staff (1)4 30 min.

Support of 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.

In plant 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 (1) 3 30 min.

Electrical TSC Manager/ TSC Engineering staff (1) 60 min.

Mechanical TSC Manager I TSC Engineering staff (1) 60 min.

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

Rad Waste operator AOICRO (1) 60 min.

Electrical Maintenance I Shift AO (1"*) On Shift Instrumentation & Control Maintenance (1) 30 min.

Technician Maintenance (1) 60 min.

Instrumentation & Control Maintenance (1) 30 min.

Technician I Emergency Plan Revision 54 Page 62 of 125 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**) 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, dosimetry Fire Fighting Fire brigade* (5**) 1 On Shift Local support 30 min.

Local support 60 min.

Rescue Operations Fire brigade (2**) On Shift

& First Aid Local support 30 min.

Local support 60 min.

Site Access Control Security, 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.

Position staffed in accordance with Technical Requirements Manual and Administrative procedures.

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 staffed.

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 Manager (STA for ENVY)

NOTES

1. AP 0894 specifies minimum shift staffing requirements. FB requires 5 persons per TRM and the Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis. The staffing analysis is maintained as a controlled document and is effective 30 days after OSRC approval. STA and Chemistry Tech must be available within 10 minutes to the Control Room. VY letter to NRC dated 4/14/1981 (FVY 81-65) establishing position. VY letter to NRC 6/22/1982 (FVY 82-75)

Supplement -NUREG 0737 Item III.A.1.2 on training of on-shift staff to support VY position for staffing. VY letter to NRC 4/14/1981 (FVY 81-65) TMI Action Plan Item II1.A.1.2, goal for augmentation of staff. VY letter to NRC 6/15/82 (FVY 82-70) 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. AOs are trained to self-monitor in an emergency.

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, CRS, STA, and Chem Tech 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 54 Page 63 of 125 Entergy Vermont Yankee

I I

i Security L

I I I

- -No Corrective action repair is performed by Auxiliary I Operations Staff on-shift until Operators osupplemented by emergency response peo organization.

/x/ = Number of Individuals Figure 8.1 Normal On-shift Emergency Organization.

Emergency Plan Revision 54 Page 64 of 125 Entergy Vermont Yankee

Figure 8.2 VY Emergency Management Organization Emergency Plan Revision 54 Page 65 of 125 Entergy Vermont Yankee

Maintenance Cori ntr Engieerng Coordinator' E : Radiological dnator Operations Codntr required for activatior Figure 8.3 Technical Support Center Emergency Organization Emergency Plan Revision 54 Page 66 of 125 Entergy Vermont Yankee

0 0 OSC Manager*

OSC Log Keeper ' Coordinator Operations Mechanical RadChemnL &LEetia Coordinator Coordinator Coordinator required for activation Figure 8.4 Operations Support Center Emergency Organization Emergency Plan Revision 54 Page 67 of 125 Entergy Vermont Yankee

ComuicatoZsor CommuicatoW Dose Assessment Team

• required for activation Figure 8.5 Emergency Operations Facility Organization Emergency Plan Revision 54 Page 68 of 125 Entergy Vermont Yankee

00 Spokesperson* I

]nr j Technical Advisor I I

• required for activation Figure 8.7 Joint Information Center Organization Emergency Plan Revision 54 Page 69 of 125 Entergy Vermont Yankee

9.0 EMERGENCY RESPONSE 9.1. Emergency Condition Recognition and Classification Vermont Yankee maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and promptly declares the emergency condition as soon as possible following identification of the appropriate emergency classification level.

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 and the 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 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 Emergency Organization The Shift Manager 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: Notification of Unusual Event, Alert, Site Area Emergency, or General Emergency.

Emergency Plan Revision 54 Page 70 of 125 Entergy Vermont Yankee

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

The response required as a result of this declaration of a Notification of 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 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. Additional personnel report to the plant as requested by the SM;

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

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 Emergency Plant Manager; Emergency Plan Revision 54 Page 71 of 125 Entergy Vermont Yankee

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

14. The Shift Manager terminates the Notification of Unusual Event status and closes out the event with a verbal summary to offsite authorities or escalates to higher level emergency classification.

9.2.1.1. Unusual Event (Terminated) Response If a condition that warrants a Notification of Unusual Event declaration has occurred, and was immediately rectified such that the condition no longer existed by the time of declaration, this Notification of 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 a Notification of Unusual Event. All the same notifications for a Notification of Unusual Event are made, and emergency response personnel reporting to the plant are based on specific requests of the SM.

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 Notification of 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 FacilitylRecovery Center, and the Joint Information Center are activated by personnel as shown in Table 9.1;

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

4. The Emergency Plant Manager reports to the Technical Support Center and directs in-plant emergency operations;

5. The EOF Manager establishes operations in the EOF/RC; Emergency Plan Revision 54 Page 72 of 125 Entergy Vermont Yankee

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 Emergency Director reports to the EOF/RC and assumes total responsibility for overall emergency response actions and recovery;

8. The Joint Information Center is established and timely public information is presented through coordination between the Emergency Director and offsite authorities;

9. 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

10. The Emergency Director 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 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. The Engineering Support Group works in concert with the TSC to resolve engineering support and assist in coordinating equipment resources;

3. State emergency response personnel are dispatched to the EOF/RC as state/local emergency response organizations become fully mobilized;

4. 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;

5. 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 54 Page 73 of 125 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 Emergency Director 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 Emergency Director may request that the EOF Manager mobilize other personnel in support of Vermont Yankee through activation of the Corporate Emergency Center;

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

3. The full resources of the National Response Framework 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. Emeraqency 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 54 Page 74 of 125 Entergy Vermont Yankee

De-escalation from a Notification of 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. Notification of Unusual Event conditions have been reviewed, are under control, and are not expected to deteriorate further.

De-escalation from emergency classes greater than the Notification of 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 Emergency Director 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 Emergency Director 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 54 Page 75 of 125 Entergy Vermont Yankee

TABLE 9.1 (Page 1 of 2)

VERMONT YANKEE EMERGENCY RESPONSE EMERGENCY CENTER NOTIFICATION OF UNUSUAL EVENT ALERT OR SITE AREA OR GENERAL EMERGENCY Technical Support Center Activation at the discretion of the Emergency Plant Manager Emergency Plant Manager TSC Manager Maintenance Coordinator (Electrical/Mechanical/&C)

Radiological Coordinator Reactor Engineer Engineering Coordinator (Project, System, Design)

Operations Coordinator Engineering Support Group Operations Support Center Not activated OSC Manager Radiation Protection Staff Chemistry Staff Spare Licensed Operators Spare Auxiliary Operators Control Instrument Specialists Plant Mechanics Emergency Plan Revision 54 Page 76 of 125 Entergy Vermont Yankee

TABLE 9.1 (Continued)

(Page 2 of 2)

VERMONT YANKEE EMERGENCY RESPONSE NOTIFICATION OF UNUSUAL ALERT OR SITE AREA OR GENERAL EMERGENCY CENTER EVENT EMERGENCY Emergency Operations Activation at the discretion of the Facility/Recovery Center Emergency Plant Manager Emergency Director Offsite Communicator Technical Advisor EOF Manager Administration and Logistics Coordinator Radiological Assessment Coordinator Personnel & Equipment Monitor

• Site/Offsite Monitoring Teams Public Information Liaison Joint Information Center Not Activated Company Spokesperson VY Public Information Staff Nuclear Public Information Representatives Joint Information Center Staff

• Deployed from OSC and report to Radiological Assessment Coordinator Emergency Plan Revision 54 Page 77 of 125 Entergy Vermont Yankee

SHIF T:ýMANA PER Classi indident and I IInForm/NAS "STATE POLICE 3 STATES

ý:.::NofifyState.Authorities and Implement State RaOdioogical Emergency Respnse Plan. I NRCR mplements National Response Framework.

I I

PLANT RESPONSE PERSONNEL-Respond as assigned Figure 9.1 Notification Plan Emergency Plan Revision 54 Page 78 of 125 Entergy Vermont Yankee

10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES 10.1. Radiological Assessment 10.1.1. Initial Offsite Radiological Dose Projection Capability Vermont Yankee has developed a method 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 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).

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.

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.

Emergency Plan Revision 54 Page 79 of 125 Entergy Vermont Yankee

Additionally, the Offsite Dose Nomogram can be used to determine an activity release rate (piCi/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;

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 assumptions incorporated in and the use of the nomograms contained in Figure 10.1 is discussed in Appendix C.

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. If the 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 as described in section 6.2.6.

Emergency Plan Revision 54 Page 80 of 125 Entergy Vermont Yankee

10.2. Protective Action Recommendation 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 Shift Manager or Emergency Director, 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, 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 inplant (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 is 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, the Vermont Yankee Emergency Director or designee provides projected offsite Total Effective Dose Equivalents (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 Emergency Director 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 implement the appropriate ingestion pathway protective actions in accordance with the FDA/HHS document Accidental Radioactive Contamination of Human Food and Animal Feeds, issued 8/13/98. Table 10.1.2 lists the Recommended Derived Intervention Level (DIL) for each radionuclide group.

10.3. Radiological Exposure Control During a plant emergency, abnormally high levels of radiation and/or radioactivity may be encountered. These levels may range from 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.

Emergency Plan Revision 54 Page 81 of 125 Entergy Vermont Yankee

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 Manager initially has the responsibility to authorize emergency dose commitments until relieved by the Emergency Plant Manager. This authorization is coordinated with the assistance of the Radiological Coordinator 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 Radiological Coordinator 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 DLR 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 DLR badge data, as soon as they can be processed at the Emergency Operations Facility/Recovery Center. The capability exists for the emergency processing of DLRs on a 24-hour per day basis, if necessary, through a General Services Agreement with Landauer Inc. Emergency workers are instructed to read self indicating dosimeters frequently, and DLRs may be processed with increased periodicity.

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 of an Alert or higher. Accountability for a Notification of Unusual Event is at the discretion of the Emergency Plant Manager. 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 Managers 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 Emergency Plant Manager 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 54 Page 82 of 125 Entergy Vermont Yankee

10.4.2. Site Egress Control Methods 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. Ifa 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. Ifconditions warrant alternative means, the EOF/RC has emergency decontamination capability (decontamination shower with the waste draining in to a 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. Contaminated personnel not required for EOF activation will be directed to State Reception Centers.

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 Iodide is assigned to emergency response organization members in accordance with established plant radiation protection criteria. Radiation guideline action 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 54 Page 83 of 125 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 station procedures.

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.

10.6. Protective Actions for Onsite Personnel A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to safely shut down the reactor and perform the functions of the emergency plan.

Emergency Plan Revision 54 Page 84 of 125 Entergy Vermont Yankee

TABLE 10.1.1 EPA PROTECTIVE ACTION GUIDELINES Total Effective Dose Committed Dose Protective Action Equivalent (TEDE) Equivalent (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 SUBSEQUENT TO THE ISSUANCE OF THE PAR BY VY.)

Emergency Plan Revision 54 Page 85 of 125 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-103 + Ru-106' C + C_. <1 * + C.6_<1 6800 450 180,000 12,000 Notes:

The DIL for each radionuclide group (except for Ru-1 03 + Ru-1 06) 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-103 and Ru-1 06, respectively.

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

Recommendations for State and Local Agencies, Table 2, 8/13/98)

Emergency Plan Revision 54 Page 86 of 125 Entergy Vermont Yankee

TABLE 10.2 EMERGENCY DOSE LIMITS(a)

(refer to Notes 1 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 25_____Rem ______TEDE______ Large Population Lifesaving or Protection of Only on a voluntary basis to 75 Rem TEDE Large Population persons fully aware of the risks 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 ipractical 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 10CFR 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 54 Page 87 of 125 Entergy Vermont Yankee

TABLE 10.3 EMERGENCY CENTER HABITABILITY AND PROTECTIVE 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 1 Rem on the high-range or alarming dosimeter will initiate planning for possible evacuation to the alternate center.

a) If the TSC has to be evacuated, I) The Emergency Plant Manager 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 Administration and Logistics Coordinator.

b) If the 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. If center personnel have been or may be exposed to elevated radioiodine air concentrations in excess of 500 millirem/hr (4.0 x 10-6 microcuries/cc), evaluate the need for administration of KI for center staff and relief shift personnel.

Emergency Plan Revision 54 Page 88 of 125 Entergy Vermont Yankee

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Figure 10.1 Vermont Yankee Emergency Dose Rate Nomogram Emergency Plan Revision 54 Page 89 of 125 Entergy Vermont Yankee

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Figure 10.2 Field Sample Thyroid Dose Nomogram Emergency Plan Revision 54 Page 90 of 125 Entergy Vermont Yankee

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Figure 10.3 Medical Facilities within 50 Miles of Vermont Yankee Capable of Handling Emergency Medical Cases Emergency Plan Revision 54 Page 91 of 125 Entergy Vermont Yankee

11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 11.1. Emergency Notification The Shift Manager 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 procedure, the Department of Public Health of Vermont, Massachusetts and New Hampshire may call Vermont Yankee and 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);

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 54 Page 92 of 125 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 Information Center for the purpose of providing coordinated press releases during an accident.

For a Notification of Unusual Event, the Manager of Communications is notified of the incident by telephone or paging system. The Manager of Communications, 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 Manager of Communications notifies the appropriate departmental staff and the corporate public affairs office.

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

The Public Information Liaison and required staff report to the EOF/RC for coordinating the accident information between the plant and the Joint Information Center. The Joint Information Center is staffed and provides immediate accessibility to information files and resources for the Company Spokesperson (Manager of Communications, or designated alternate) and/or the Joint Information Center staff.

Regular press conferences are held at the Joint Information Center, directed by the Company Spokesperson in conjunction with appropriate state and federal organizations.

Vermont Yankee can provide 24-hour coverage at the Joint Information 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 operation, 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 Information Center personnel monitor local radio and television for erroneous information concerning accident conditions. When misinformation is recognized, corrective action is taken.

Emergency Plan Revision 54 Page 93 of 125 Entergy Vermont Yankee

Communication is provided between the Joint Information 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 Communications 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.

Emergency Plan Revision 54 Page 94 of 125 Entergy Vermont Yankee

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. A drill 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 response organizations are operable, communications tests are conducted as outlined below. 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 Headquarters Operations Officer from the Control Room, TSC and EOF are tested monthly.

Emergency Plan Revision 54 Page 95 of 125 Entergy Vermont Yankee

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

Weekly functional test of the emergency notification system to test system performance, and Quarterly 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 Emergency Plan drill or exercise.

Emergency Plan Revision 54 Page 96 of 125 Entergy Vermont Yankee

12.1.7. Security Drills The purpose of the Hostile Action-based drill is to maintain key skills, specifically the site-specific team skills necessary to mitigate security-based events. Hostile Action-based scenarios will be included in the drill and exercise program for exercise selection on a six-year frequency. Full implementation should include engagement of Offsite responders and FEMA. Scenarios should address EP response actions early in the event that include aspects such as initial classification, notification, PARs if appropriate, and protective measures on site. Various scenarios should be developed to address response to different threat modes, various initiators or response capabilities.

12.1.8. 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 include, but are 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.

Emergency Plan Revision 54 Page 97 of 125 Entergy Vermont Yankee

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.

12.1.9. 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.

12.1.10. 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 Entergy Quality Assurance Program in accordance with 10CFR50.54(t). All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.

Emergency Plan Revision 54 Page 98 of 125 Entergy Vermont Yankee

12.2. Training All non-essential plant personnel receive annual instruction, in accordance with "Emergency Plan Training," 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 "Emergency Plan Training," and in the Emergency Plan Training Program Description.

12.3. Review and Updatina 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 10CFR50.54(q). The Emergency Plan is submitted to Vermont Yankee's On-Site Safety Review Committee for approval. Written agreements with outside support organizations and government agencies are evaluated annually 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 Emeraencv EauiDment 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 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 Site 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 AND EMERGENCY ACTION LEVELS

[NOTE: Reference AP 3125, Emergency Plan Classification and Action Level Scheme for the most current revision of the EAL Charts.]

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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 referenced in 6.2.6 and 10.3 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 EOF/RC HOUSE HOUSE Respiratory Protection Radiation Monitoring Dosimetry 0 0 0 Sampling Communications Dose Assessment Area Map/Status Boards

-Emergency References ***

Protective Clothing *

=mDecontamination 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 listing of emergency equipment is provided in OP 3506, "Emergency Equipment Readiness Check")

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APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATION Provided by other non-affected Entergy nuclear sites, State and EQUIPMENT Federal agencies and other utilities through INPO as needed Gamma Spectroscopy High Pressure Ion Chamber Mobile Processing DLR Unit Personnel &

Environmental DLR Badges Emergency Plan Revision 54 Page 104 of 125 Entergy Vermont Yankee

APPENDIX C INITIAL OFFSITE DOSE RATE ESTIMATION Emergency Plan Revision 54 Page 105 of 125 Entergy Vermont Yankee

APPENDIX C (Continued)

Vermont Yankee has developed a method to quickly determine the release rate and the 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 least 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.

• Emergency Plan Revision 54 Page 106 of 125 Entergy Vermont Yankee

APPENDIX D ENVIRONMENTAL LABORATORY ANALYTICAL AND DOSIMETRY SERVICES Emergency Plan Revision 54 Page 107 of 125 Entergy Vermont Yankee

APPENDIX D (Continued)

General In the event of a radiological emergency at Vermont Yankee, Laboratory services (as described in 6.2.6) are available, on a 24-hour emergency call basis, to perform gamma isotopic analyses on samples taken by the plant's emergency monitoring teams. Portable gamma spectroscopy equipment can be deployed to the 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 Entergy maintains a General Services Agreement with Landauer Inc. for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> emergency personnel Dosimetry processing.

Portable Emeraency Analysis Equipment Portable analysis equipment including a shielded HPGe detector based gamma spectroscopy system complete with computerized spectral analysis capability may be deployed to assist in an emergency response. A report of plant-related nuclide concentrations, standard deviation, and Minimum Detectable Concentration (MDC) is forwarded to assessment personnel.

Following a request from Vermont Yankee for assistance in assessing an emergency condition, laboratory personnel will be dispatched to a designated location within approximately four (4) to eight (8) 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 DLR Services The capability exists for the emergency processing of DLRs on a 24-hour per day basis, if necessary, through a General Services Agreement with Landauer Inc. Emergency workers are instructed to read self indicating dosimeters frequently, and DLRs may be processed with increased periodicity.

Portable Body Burden Service A WBC System is comprised of a portable shielded HPGe detector, interfaced to a PC-based ADCI/MCA and IBM compatible portable computer may be acquired from the other industry facilities. 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.

Emergency Plan Revision 54 Page 108 of 125 Entergy Vermont Yankee

APPENDIX E LETTERS OF AGREEMENT Letters of agreement in effect between Vermont Yankee and the offsite authorities and organizations, which under earlier revisions resided in this appendix, have been removed.

These documents are now maintained in the Emergency Planning Department files.

Entergy Operations, Inc. maintains agreements and/or contracts with the following organizations in support of Vermont Yankee Emergency Response.

Letters of Agreement have been ascertained with offsite groups to provide on-site aid in the event of an emergency situation, including those resulting from hostile actions at Vermont Yankee.

Ambulance Service: Twenty-four (24) hour ambulance service is provided by Rescue Inc.

Mutual aid backup from other ambulance services provides for additional emergency medical services, ambulances and EMS personnel. Onsite procedures contain instructions that cover the call for assistance and the handling of the ambulance service personnel.

Radio communication exists between the ambulance and local hospitals.

Medical: Onsite procedures contain instructions, which cover the request for medical assistance and handling of patients.

Hospitals: Brattleboro Memorial Hospital and Baystate Franklin Medical Center have agreed to accept patients from Vermont Yankee who have been injured, contaminated or irradiated.

Fire: Offsite firefighting support is provided by the Vernon and Brattleboro Fire Departments, as resources permit, with mutual aid backup from other fire departments.

Law Enforcement: When notified that assistance is needed, Security will notify the Lead Local Law Enforcement Agency (LLEA). The handling of security matters, including those involving hostile action for Vermont Yankee is covered in the Vermont Yankee Security Plan and are classified as safeguards information.

Emergency Plan Revision 54 Page 109 of 125 Entergy Vermont Yankee

APPENDIX E (Continued)

. Letters of Agreement I 1. State of Massachusetts

2. State of New Hampshire

3. State of Vermont

4. Baystate Franklin Medical Center

5. National Weather Service (NOAA) 6 Brattleboro Memorial Hospital

7. Rescue, Inc. Ambulance Service

8. Vernon Fire Department

9. Brattleboro Fire Department

10. Institute of Nuclear Power Operations

• 11. Town of Vernon

12. Department of Energy

13. DOE - REAC/TS

14. Deleted

15. State of Massachusetts Alert & Notification System

16. State of New Hampshire Alert & Notification System

17. State of Vermont Alert & Notification System

18. Landmark College

19. 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.

O Emergency Plan Revision 54 Page 110 of 125 Entergy Vermont Yankee

APPENDIX F EVACUATION TIME ESTIMATES The Evacuation Time Estimate for Vermont Yankee Nuclear Power Station is maintained as a separate document. The Evacuation Time Estimate is provided to offsite agencies when it is updated.

Emergency Plan Revision 54 Page 111 of 125 Entergy Vermont Yankee

APPENDIX G INDEX OF EMERGENCY PLAN IMPLEMENTING PROCEDURES AND SUPPORT PLANS Emergency Plan Revision 54 Page 112 of 125 Entergy Vermont Yankee

APPENDIX G (Continued)

I. EMERGENCY PLAN IMPLEMENTING PROCEDURES AP 3125 Emergency Plan Classification and Action Level Scheme EPOP-COMM-3504 Emergency Communications EPOP-EQUIP-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 I EPOP-PAR-3511 OP 3513 Offsite Protective Action Recommendations Evaluation of Offsite Radiological Conditions 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 EPOP-CR-3540 Control Room Actions During an Emergency EPOP-TSC-3542 Operation of the Technical Support Center EPOP-OSC-3544 Operation of the Operations Support Center EPOP-EOF-3546 Operation of the Emergency Operations Facility/Recovery Center OP 3547 Security Actions During an Emergency OP 3548 Emergency Termination and Recovery AP 3549 Offsite Emergency Preparedness Support EPOP-JIC-3550 Activation and Operation of the Joint Information Center EPOP-3551 Operation of the Joint Information Center When the Alternate Joint Information Center is Activated EPOP-3552 Activation and Operation of the Alternate Joint Information Center AP 3553 Administration and Maintenance of the Alert and Notification System AP 3554 Emergency Plan Teams AP 3712 Emergency Plan Training AP-10049 Equipment Important to Emergency Response EPAP-INFORM-10076 InForm Notification System Emergency Plan Revision 54 Page 113 of 125 Entergy Vermont Yankee

APPENDIX G (Continued)

II. SUPPORT PLANS*

The Vermont Yankee Severe Accident Management Program (PP 7019)

The Vermont Yankee Security Plan Vermont Yankee Fire Protection and Safe Shutdown (SEP-FP-VTY-003)

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 NRC Incident Response Plan (NUREG-0728)

National Response Framework (January 2008)

Procedure for Admission and Management of Radioactively Contaminated Patients at Brattleboro Memorial Hospital Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis Evacuation Time Estimate Corporate Support Procedures EN-FAP-EP-009, Use of KI for the Emergency Response Organization EN-FAP-EP-010, Severe Weather Response EN-FAP-EP-012, Severe Weather Recovery EN-EP-202, Equipment Important to Emergency Preparedness EN-EP-301, Emergency Planning Assessment of Offsite Emergency Response Capability Following a Natural Disaster EN-EP-305, Emergency Planning 10CFR50.54(q) Review Program EN-EP-306, Drills and Exercises EN-EP-307, Hostile Action Based Drills & Exercises EN-EP-308, Emergency Planning Critiques EN-EP-309, Fatigue Management for Hurricane Response Activities EN-EP-31 0, Emergency Response Organization Notification System EN-EP-31 1, Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)

EN-EP-401, Public Use of Emergency Preparedness Owner Controlled Area EN-EP-601, Corporate Emergency Center Operations EN-EP-606, Pandemic Flu Response EN-EP-801, Emergency Response Organization This list does not reference any of the emergency plan arrangements specified in Appendices D and E of this plan.

Emergency Plan Revision 54 Page 114 of 125 Entergy Vermont Yankee

APPENDIX H PUBLIC NOTIFICATION SYSTEM Emergency Plan Revision 54 Page 115 of 125 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 37 sirens and NWS Tone-Alert receivers. The attached town maps indicate the location of each siren.

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 Alert System (EAS) 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.

Emergency Plan Revision 54 Page 116 of 125 Entergy Vermont Yankee

APPENDIX H (Continued)

Siren List Map # Siren Name Siren Location 1 WI Vermont Yankee, Vernon, VT 2 W2 Fire Station, Vernon, VT 3 W3 Recreation Center, Vernon, VT 4 BV1 Municipal Center, Brattleboro, VT 5 BV2 Town Garage, Brattleboro, VT 6 BV3 West Fire Station, Brattleboro, VT 7 BV4 Putney Road, Brattleboro, VT 8 BV5 Williams Street, Brattleboro, VT 9 BV6 State Police, Route 9, Brattleboro, VT 10 HNI Fire Station, Hinsdale, NH 11 HN2 Town Well, Hinsdale, NH 12 WN1 Swanzey Town Line, Route 10, Winchester, NH 13 WN2 Fiddle Hill Road, Winchester, NH 14 WN3 Fire Station, Winchester, NH 15 WN4 Town Well, Route 10, Winchester, NH 16 NM1 Route 10 North, Northfield, MA 17 NM2 Fire Station, Northfield, MA 18 NM3 Lucky Clapp Road, Northfield, MA 19 DM1 Town Garage, Bernardston, MA 20 CM1 Griswoldville, Colrain, MA 21 CM2 Aunt Sophie's Peak, Colrain, MA 22 DM2 Hucklehill Road, Bernardston, MA 23 CM3 Greenfield and Leyden Roads, Colrain, MA 24 CN1 Fire Station Cupola, Chesterfield, NH 25 CN2 West Chesterfield Fire Station, Chesterfield, NH 26 CN3 Spofford Fire Station, Chesterfield, NH 27 CN4 Highway Garage, Chesterfield, NH 28 DV1 Highway Garhge, Dummerston, VT 29 DV2 West Dummerston Fire Station, Dummerston, VT 30 DM3 Fire Station, Bernardston, MA 31 GM1 Northfield Mt, Hermon School, Gill, MA 32 LM1 Municipal Center, Leyden, MA 33 GV1 Front of School Corner, Guilford, VT 34 GV2 Stage Road, Guilford, VT 35 GV3 Sportsman's Club on Cremery Road, Guilford, VT 36 HN3 Filter Plant, Route 63, Hinsdale, NH 37 RN1 Whipple Hill Road, Richmond, NH Emergency Plan Revision 54 Page 117 of 125 Entergy Vermont Yankee

APPENDIX H (Continued) 10 0 0 '4 Z 3/4 MI!n 1 11/

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