BVY 14-018, Proposed Changes to Emergency Plan

Proposed Changes to Emergency Plan

ML14085A257
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	03/24/2014
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-018
Download: ML14085A257 (146)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee Entergy 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President 10 CFR 50.90 10 CFR 50.54(q)(4)

BVY 14-018 March 24, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Proposed Changes to the.Vermont Yankee Emergency Plan Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCE:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) requests an amendment to Renewed Facility Operating License Number DPR-28 for Vermont Yankee Nuclear Power Station (VY). The proposed amendment would revise the site emergency plan (SEP) for the permanently defueled condition. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).

The proposed SEP changes would revise the on-shift staffing and Emergency Response Organization (ERO) staffing. ENO has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E and concludes that the standards and requirements will continue to be met.

On September 23, 2013, ENO informed the NRC that VY will permanently cease operations at the end of the current operating cycle, which is expected to occur in the fourth quarter of 2014 (Reference 1). Upon docketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)),

pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel.

The proposed changes to the SEP are commensurate with the reduced spectrum of credible accidents in the permanently defueled condition. In order to assist in the transition from an operating facility to a permanently defueled facility, the changes are required to properly reflect the

BVY 14-018 / Page 2 of 3 conditions of the facility while continuing to preserve the VY Decommissioning Trust Fund and the effectiveness of the SEP.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and ENO has determined that this change involves no significant hazards consideration. ENO has also determined that the proposed SEP changes satisfy the criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9) and do not require an environmental review. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required.

The description and evaluation of the proposed SEP changes are contained in Attachment 1. provides a tabular summary of the proposed changes to the SEP. Attachment 3 provides the revised pages of the SEP with the proposed changes. Attachment 4 provides the post-shutdown on-shift staffing analysis. Attachment 5 provides the analysis of Emergency Response Organization (ERO) tasks that will be transferred to remaining ERO positions. of this letter contains a new regulatory commitment.

In accordance with 10 CFR 50.91(b)(1), a copy of this application, with attachments, is being provided to the designated state of Vermont official.

ENO requests review and approval of the proposed license amendment by January 1, 2015 with a 60 day implementation period. Approval of these changes by this date will allow VY adequate time to implement changes to the emergency plan and emergency response organization following completion of defueling activities. ENO requests that the approved amendment become effective upon docketing of the certifications required by 10 CFR 50.82(a)(1).

If you have any questions on this transmittal, please contact Mr. Coley Chappell at 802-451-3374.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 24, 2014.

Sincerely, CJW/plc Attachments: 1. Description and Evaluation of Proposed Changes

2. Tabular Summary of Proposed Changes to Site Emergency Plan

3. Proposed Revision to Site Emergency Plan Pages

4. Analysis of Proposed Post-Shutdown On-Shift Staffing

5. ERO Task Analysis

6. List of Regulatory Commitments

BVY 14-018 / Page 3of3 cc: Mr. William M. Dean Region 1 Administrator U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601

BVY 14-018 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Description and Evaluation of Proposed Changes

BVY 14-018 / Attachment 1 / page 1 of 23

1.

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Renewed Facility Operating License (OL) DPR-28 for Vermont Yankee Nuclear Power Station (VY).

The proposed changes would revise VY Site Emergency Plan (SEP) on-shift and Emergency Response Organization (ERO) staffing to support the planned permanent cessation of operations and permanent defueling of the VY reactor (Reference 1).

A post-shutdown on-shift staffing assessment (OSA) was performed to provide the basis for the proposed changes to the on-shift staffing. VY currently has one (1) Shift Manager (SM), one (1)

Control Room Supervisor (CRS), two (2) Control Room Operators (CRO), six (6) Auxiliary Operators (AOs), one (1) Radiation Protection Technician, one (1) Chemistry Technician and one (1) Shift Technical Advisor (STA) on shift. The post-shutdown OSA shows that an on-shift complement of one (1) SM, one (1) CRS/Certified Fuel Handler (CFH), one (1) Radiation Protection Technician and three (3) CROs/AOs/Non-Certified Operators (NCOs) will be required in the permanently defueled condition since the consequences of credible events will be reduced when compared to the events that can occur with an operating reactor.

The number of on-shift and ERO staff at VY following permanent defueling will be reduced from current normal operating levels, but are commensurate with the need to safely store spent fuel at the facility in a manner that is protective of public health and safety.

ENO has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and has concluded that the standards and requirements will continue to be met. Therefore, no exemption from 10 CFR 50.47 or 10 CFR 50, Appendix E is requested.

2. PROPOSED CHANGES The proposed changes would revise the SEP to reflect the permanently shutdown and defueled condition. Specifically, the proposed changes would eliminate the on-shift positions not needed for the safe storage of spent fuel in the spent fuel pool (SFP) during the initial decommissioning period and eliminate the ERO positions not necessary to effectively respond to credible accidents.

Attachment 2 provides a tabular summary of the proposed changes to the SEP. Attachment 3 provides the revised pages of the SEP with the proposed changes shown in strikethrough and underline format. The changes shown in Attachments 2 and 3 include additional changes beyond those involving a reduction in staffing. NRC approval of these additional changes is not being requested. These additional changes are included for informational purposes.

On-Shift Staffing Currently, SEP Table 8.4, "Minimum Staffing Requirements for the ENVY ERO," specifies the on-shift and augmented staffing for certain positions in the following Major Functional Areas:

• Plant Operations & Assessment of Operational Aspects

• Emergency Direction & Control

• Notification/Communication

• Radiological Accident Assessment and Support of Operational Accident Assessment

• Plant System Engineering

• Repair & Corrective Actions

• In-Plant Protective Actions

BVY 14-018 / Attachment 1 / page 2 of 23

• Fire Fighting

• Rescue Operations & First Aid

• Site Access Control & Personnel Accountability The proposed changes to the SEP will eliminate the following on-shift positions:

• Two (2) CROs

• Three (3) AOs

• STA

• Chemistry Technician Operations on-shift personnel will consist of one (1) SM, one (1) CRS/CFH and three (3)

CROs/AOs/ NCOs. Title changes for the CRS and CRO/AO to CFH and NCO, respectively, are dependent upon NRC approval of proposed changes to the VY Technical Specifications (Reference 2) that revise the minimum shift staffing requirements in the VY Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs. These staffing levels have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition. The analysis is provided in Attachment 4 of this submittal.

The term NCO is used to differentiate from CFH. CFHs will supervise fuel handling operations in the permanently defueled condition. CRSs and SMs will be qualified as CFHs. However, the SM requires additional qualification beyond the CFH training. Therefore, any reference to the CFH position throughout this submittal is considered to be equivalent to the current CRS position. NCOs will perform duties typically associated with those performed by AOs and CROs, such as manipulation and monitoring of plant equipment. NCOs will also be assigned to monitor indications and communications in the Control Room. Reference 3 submitted a CFH training program for NRC approval. Dedicated CROs will not be utilized in the permanently defueled condition.

The proposed changes to the on-shift organization are identified in Section 8.1, "Normal Plant Organization," of the SEP, Table 8.4, and Figure 8.1, "Defueled On-Shift Emergency Organization."

Emergency Response Organization Staffing Currently, SEP Table 8.4 specifies the on-shift and augmented staffing for certain positions in the Major Functional Areas identified above. The proposed changes to the SEP will eliminate the augmented Technical Support Center (TSC) Reactor Engineer position identified in Section 8.2.2, "Emergency Plant Manager" and Table 8.4. The TSC Reactor Engineer is also identified in Table 9.1, "Vermont Yankee Emergency Response," as a position notified at an Alert, Site Area Emergency or General Emergency and required to activate the TSC.

The proposed changes to the SEP will also eliminate non-minimum (i.e., not required for facility activation) ERO positions currently identified in Table 8.3, "A Summary of Offsite Coordination,"

Figure 8.2, "VY 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 8.7, "Joint Information Center Organization," and Table 9.1, "Vermont Yankee Emergency Response" Specific positions identified for elimination are listed in Table 1 of this attachment.

BVY 14-018 / Attachment 1 / page 3 of 23

3. REASON FOR PROPOSED CHANGES The proposed changes are desired to reflect the pending permanent cessation of operation and permanent defueling of the VY reactor at the end of the current operating cycle. After the reactor is shut down, all fuel assemblies will be removed from the reactor vessel and placed in the SFP. The irradiated fuel will be stored in the SFP and in the Independent Spent Fuel Storage Installation (ISFSI) until it is shipped off-site in accordance with the schedules that will be described in the Post-Shutdown Decommissioning Activities Report (PSDAR) and updated Irradiated Fuel Management Plan. Upon docketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)),

pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel.

The proposed revisions to the SEP are commensurate with the reduction in hazards associated with the permanently defueled condition and will allow the facility staff to transition from that required for an operating facility to that required for a permanently defueled facility. The proposed changes are required to properly reflect the conditions of the facility while continuing to preserve the VY Decommissioning Trust Fund and the effectiveness of the SEP.

4. BACKGROUND On-Shift and ERO Staffinq NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," (Reference 4),Section II.B, "Onsite Emergency Organization," presents guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies." This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response functions where the duties may be performed by shift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions). Table B-1 specifies two Major Functional Areas (i.e., firefighting and site access control/personnel accountability) which must be staffed on a site-specific basis.

The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the site's emergency plan commitments. The augmenting ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations.

On November 23, 2011, the NRC published a final rule in the Federal Register amending certain emergency preparedness (EP) requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 5). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, "Organization," to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions. Specifically,Section IV.A.9 states that licensees shall perform

"...a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan."

Coincident with the rule change in 10 CFR 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants" (Reference 6). This Interim Staff Guidance (ISG) provides information relevant to performing the

BVY 14-018 / Attachment 1 / page 4 of 23 on-shift staffing analysis. The ISG states that the Nuclear Energy Institute (NEI) developed NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities,"

(Reference 7) to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

4.1 VY Specific Background On-Shift Staffing In December 2012, an OSA was performed in accordance with the NEI 10-05 guidance to satisfy the requirements of 10 CFR 50, Appendix E Section IV.A.9. This analysis examined the capability of the minimum staff listed in Table 8.4 of the SEP to perform the key emergency response actions for events described in the ISG until augmenting ERO staff arrive. The analysis was conducted by a cross disciplinary team of corporate EP personnel and station personnel from the Operations, Training, Radiation Protection (RP), Chemistry, Licensing and EP departments. The emergency response to each of the events described in the ISG was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable departmental procedures such as emergency and off normal procedures. Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for emergency response implementation as described in Table 8.4, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency response role or their dedicated operational role, as appropriate. In cases where multiple tasks were assigned to an individual, the team evaluated the timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements. The Design Basis Accident scenarios considered in this OSA were the control rod drop accident (CRDA), loss of coolant accident (LOCA), main steam line break (MSLB) accident and fuel handling accident (FHA).

The OSA was updated in December 2013 and concluded that an on-shift staff of thirteen is required to respond to the most limiting accident scenario, which was determined to be a Control Room fire and plant shutdown at the remote shutdown panel.

SEP Table 8.4 specifies the minimum staffing requirements for the VY ERO and defines the positions initially responsible for satisfying key ERO functions and specifies positions that will augment the on-shift staff.

Emergency Response Organization Staffing The VY SEP defines four classes of emergency events; Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE) and General Emergency (GE). Because on-shift personnel can normally address an emergency response to UEs without additional support, staff augmentation is not activated for an UE declaration. The Operations SM maintains responsibility during UEs. The second classification level, Alert, requires ERO activation of all Emergency Response Facilities (ERFs). This includes the Technical Support Center (TSC), the Operations Support Center (OSC),

the Emergency Operations Facility (EOF) and the Joint Information Center (JIC). Overall responsibility for the event is assumed by the Emergency Director in the EOF. When the ERO is activated, notification is sent to those required to respond to their assigned ERF.

BVY 14-018 / Attachment 1 / page 5 of 23 VY SEP Section 8.0, "Organization," describes how the normal plant operating organization transitions into an ERO to effectively deal with any incident at VY. Section 8.1, "Normal Plant Organization," describes the normal operation organization on duty at the plant during all shifts.

The VY Emergency Management Organization is shown in SEP Figure 8.2. Staffing for the onsite emergency response facilities is shown in SEP Figure 8.3 (TSC) and SEP Figure 8.4 (OSC).

Staffing for the off-site emergency response facilities is shown in SEP Figure 8.5 (EOF/Recovery Center) and SEP Figure 8.7 (JIC). 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 SM; designated company personnel are notified and will report to designated locations. The emergency response actions 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 on-shift operations crew.

Plans and procedures have been put into place to ensure the timely activation of emergency response facilities. SEP Table 9.1 identifies the personnel required to staff and activate the TSC, OSC, the EOF/Recovery Center, and the JIC. 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.

5. TECHNICAL EVALUATION 5.1 Accident Analysis Section 14 of the VY Updated Final Safety Analysis Report (UFSAR) describes the Abnormal Operational Transients and DBA scenarios that are applicable during plant operations. Other accidents evaluated in the UFSAR include a Station Blackout (SBO) event, 10 CFR 50 Appendix R fire events and an Anticipated Transient without SCRAM (ATWS) event. Upon docketing of the certifications required by 10 CFR 50.82(a)(1), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). Therefore, most of the accident scenarios postulated in the UFSAR will no longer be applicable once VY is in the permanently defueled condition.

The postulated DBA that will remain applicable to VY in its permanently shutdown and defueled condition is the FHA in the reactor building, where the SFP is located. UFSAR Section 14 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition.

These DBAs are the CRDA, LOCA and MSLB accident.

SBO, Appendix R fire and ATWS were not considered in the post-shutdown OSA. Once the certifications required by 10 CFR 50.82(a)(1) are docketed, VY will no longer be licensed to operate and 10 CFR 50.63 (the Station Blackout Rule) will no longer be applicable pursuant to 10 CFR 50.63(a)(1). Similarly, 10 CFR 50 Appendix R is applicable to licensed nuclear power generating stations. Once the certifications required by 10 CFR 50.82(a)(1) are docketed, VY will no longer be licensed to generate nuclear power. Finally, since the Part 50 license will no longer authorize emplacement or retention of fuel in the reactor vessel, an ATWS will no longer be a credible event.

A comparison of the accident scenarios included in the current and post-shutdown OSA is provided in the next section.

BVY 14-018 / Attachment 1 / page 6 of 23 5.2 Analysis of Proposed Changes ERO Staffing In the permanently defueled condition, VY will maintain ERO teams, with one complete team being on duty and on-call at any given time. When the SM directs the activation of the ERO call out system, all ERO members are notified to ensure adequate coverage of all ERO positions at all ERFs.

VY requires members to act promptly in reporting to their assigned ERF even when not on duty.

During duty periods, the procedure further requires that team members respond within the required response time for their ERF (unless a longer time frame is specified for their specific ERO position) and that they remain fit for duty throughout the duty assignment. Individuals are trained to respond to their ERF even if they are not on duty. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift. This conservative policy ensures timely activation since some off duty personnel may respond sooner than the on duty personnel.

The proposed revisions to the SEP will not change these requirements. It will continue to be a management expectation that all duty and support ERO members report to their respective ERF as quickly as possible.

Currently, VY maintains a minimum of four (4) persons per ERO position as specified in SEP Table 8:4, Note 3. In order to provide flexibility and optimize the staff available in the permanently defueled condition, SEP Table 8.4, Note 3, is being revised to remove the minimum number of persons per ERO position and state the following:

"ENVY has designated ERO members who staff positions required to meet minimum staffing to activate the TSC, OSC and EOF. The minimum staff positions required to activate the TSC and EOF are shown in E Plan Figures 8.3 and 8.5. The OSC Manager is the only position required to activate and staff the OSC. All ERO personnel are expected to respond when notified by the emergency call-in notification system."

Emergency Preparedness Operating Procedures identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational. These positions are summarized in Table 1.

BVY 14-018 / Attachment 1 / page 7 of 23 Table 1 - Emergency Response Organization Positions Procedure Facility Current Positions Proposed Positions Current Minimum Staff Position EPOP-TSC-3542 TSC Emergency Plant Manager Emergency Plant Manager Yes TSC Manager No Operations Coordinator Operations Coordinator Yes Radiological Coordinator Radiological Coordinator Yes TSC Reactor Engineer Yes Engineering Coordinator Engineering Coordinator Yes Maintenance Coordinator Maintenance Coordinator Yes Manpower and Planning Liaison No ENS Communicator ENS Communicator No TSC Communicator No TSC Engineers No IT Specialist No EPOP-OSC-3544 OSC OSC Manager OSC Manager Yes Operations Support No I&C/Electrical Coordinator No Mechanical Coordinator No Rad/Chem Coordinator No Work Control Coordinator No OSC Log Keeper No EPOP-EOF-3546 EOF Emergency Director Emergency Director Yes EOF Manager No Technical Advisor Technical Advisor Yes EOF Communicator No Radiological Assessment Radiological Assessment Coordinator Yes Coordinator Offsite Communicator Off site Communicator Yes Public Information Liaison No Lead Offsite Liaison Lead Offsite Liaison No Offsite Team Coordinator Offsite Team Coordinator No Administration and Logistics Administration and Logistics Coordinator No Coordinator Emergency Planning Coordinator No IT Specialist No Dose Assessor Dose Assessor No Offsite Liaisons Offsite Liaisons No Personnel & Equipment Monitor Personnel & Equipment Monitor No EOF Log Keeper No EPOP-JIC-3550 JIC Company Spokesperson Company Spokesperson Yes JIC Manager JIC Manager No Information Coordinator No Press Release Writer No Logistics Coordinator No Technical Assistant No Technical Advisor Technical Advisor No JIC Log Keeper No Inquiry Response Coordinator No Inquiry Responder Inquiry Responder No Media Monitor/Status Phone No Recorder Media Monitor Media Monitor No Media Liaison Media Liaison No I Credentialing No

BVY 14-018 / Attachment 1 / page 8 of 23 These procedures will continue to assign responsibilities to ERO responders with the purposes of removing the responsibilities of coordinating with offsite responders and delivering information to the public from the Control Room, allowing operations personnel to focus on returning the plant to a safe condition.

The current SEP and the ERO staffing required by implementing procedures is intended to address the risks to public health and safety inherent in an operating reactor. The risk in the permanently defueled condition is significantly reduced. Many of the potential initiating conditions that would lead to an emergency declaration will no longer be credible. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessments and mitigation activities the TSC/OSC must perform.

Restoration of equipment supporting spent fuel cooling and inventory will be the primary focus of emergency mitigation actions for the TSC/OSC in a permanently shutdown and defueled condition.

Although ERO activation/response time requirements will be unchanged, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. The proposed changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency. Appropriate assessment and mitigation are well within the capabilities of the reduced TSC/OSC/EOF staff.

ERO duties have been reviewed and duties for eliminated positions will be transferred appropriately. The proposed staffing changes eliminate one minimum staff ERO position, the TSC Reactor Engineer. This position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary in a permanently shutdown and defueled condition. Remaining ERO positions will inherit duties from eliminated positions, but not to the extent of jeopardizing the ERF mission. Attachment 5 contains the results of the task analysis for the eliminated and remaining ERO positions.

There are two positions being eliminated that had tasks that involved interfacing with state and local officials was the EOF Manager and the JIC Logistics Coordinator. The EOF Manager briefed these officials when they arrived at the EOF. This is a duplicate effort with the Lead Offsite Liaison (which is not being eliminated). Therefore, there will be no impact on the existing interface with the elimination of the EOF Manager. The JIC Logistics Coordinator was responsible for copying and distribution of press releases in the JIC to state and local officials. This task is going to be assumed by the JIC Manager. Therefore, the elimination of the JIC Logistics Coordinator will not impact the ability to maintain the interface with state and local officials.

The proposed ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The ERFs will continue to be activated at an Alert or higher declaration.

Functional responsibilities of the positions eliminated as a result of the changes described within will be reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the SEP, site commitments and regulation.

On-Shift Staffing To support reduced staffing following permanent cessation of operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents previously submitted to the NRC using NEI 10-05 methodology (Attachment 4). The post-shutdown OSA assumed that the FHA is the only DBA that can occur. The OSA concluded that in a permanently defueled condition one (1) on-shift SM, one (1) CRS/CFH, one (1) Radiation Protection Technician and three (3) CROs/AOs/NCOs can

BVY 14-018 / Attachment 1 / page 9 of 23 perform all required SEP actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions.

For the current OSA, the following accident scenarios were included:

Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

Control Rod Drop Accident The control rod drop event results in fuel damage and radioactivity that is retained within the turbine, condensers, and the offgas system. Release to the environment is due to leakage from the various contaminated systems into the turbine building.

Loss of Coolant Accident The event results in a release of radioactive material from the reactor coolant system to the primary containment from a complete circumferential break of one of the recirculation loop lines.

Fuel Handling Accident (FHA)

The FHA is assumed to occur when the primary containment is open and the reactor vessel head has been removed. The DBA for this case involves the dropping of a fuel bundle on top of the core.

Main Steam Line Break Accident This event results in radioactive material releases outside secondary containment and was due to a complete severance of a 16-inch line leading to the turbine bypass steam chest.

Aircraft Potential Threat (50.54(hh))

Notification is received from the NRC that a potential aircraft threat exists.

Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire)

A fire occurs in the main control room requiring the evacuation of the control room and procedures implemented to remotely shutdown the reactor.

Station Blackout A loss of all offsite AC power occurs and the failure of the emergency diesel generators to start. The SM determines power cannot be restored and declares a Site Area Emergency due to the loss of off-site power.

BVY 14-018 / Attachment 1 / page 10 of 23 General Emergency (GE) with radioactive release and Protective Action Recommendation (PAR)

This event is based on the same initial conditions of the LOCA but assumes system failures meet the GE conditions of a loss of two fission product boundaries with the potential loss of the third.

For the post-shutdown OSA, the following accident scenarios were included:

Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

Fuel Handling Accident (FHA)

The postulated design basis accident that will remain applicable to VY in its permanently shutdown and defueled condition is the FHA in the reactor building where the SFP is located.

Aircraft Potential Threat (50.54(hh))

Notification is received from the NRC that a potential aircraft threat exists.

Fire requiring evacuation of the Control Room and control of service water pumos from a remote location A fire occurs requiring the evacuation of the Control Room and procedures implemented to control service water pumps from a remote location.

General Emergency (GE) with radioactive release and PAR (assumed for analysis purposes)

This event is based on the same initial conditions as the FHA, but assumes a dose that exceeds the EPA PAGs beyond the site boundary, and thus necessitates promulgation of a PAR.

The post-shutdown OSA indicates that the proposed on-shift personnel can satisfactorily implement all emergency plan functions as required by regulation without augmented ERO personnel for at least 90 minutes following an emergency declaration. The post-shutdown OSA confirmed that no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events.

Currently, the Chemistry Technician is an on-shift position per SEP Table 8.4 so that a technician is always available to immediately collect and analyze a liquid sample ifthe applicable radiation monitor is not available during a release, or as directed by the SM. When the on-shift Chemistry Technician position is eliminated, the on-shift Radiation Protection Technician will be able to perform sampling and analysis, so as to not delay information potentially needed by the SM to determine if an emergency declaration is required. For gaseous releases, the only credible scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object. Activities that could cause mechanical damage will require that a

BVY 14-018 / Attachment 1 / page 11 of 23 Chemistry Technician be on-site or the radiation monitor listed in gaseous effluent EALs is in service, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. A new regulatory commitment to revise applicable fuel handling procedures to incorporate this prerequisite is included in Attachment 6.

Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate given the permanent cessation of operations and removal of fuel from the reactor vessel.

Because of the reduced number of possible events requiring mitigating actions in the permanently defueled condition and the limited number of actions to be performed by the Control Room positions in a permanently defueled condition, no CRO or STA job tasks were noted as being required for any of the events analyzed in the post-shutdown OSA. Therefore, the CRO and STA positions can be eliminated without reducing the effectiveness of the post-shutdown SEP.

The proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continues to comply with the SEP, site commitments and regulations.

Additional analysis for each of the staffing changes associated with SEP Table 8.4 is provided in the following:

5.2.1 Major Functional Area: Plant Operations & Assessment of Operational Aspects CurrentStaffing Requirement During normal operations, the minimum staff on duty at the plant during all shifts consists of one (1) SM, one (1) CRS, two (2) CROs, six (6) AOs, one (1) STA, one (1) Radiation Protection Technician, and one (1) Chemistry Technician.

Proposed Change The following on-shift positions will be eliminated:

• Two (2) CROs

• Three (3) AOs

• STA

• Chemistry Technician Operations On-shift personnel will consist of one (1) SM, one (1) CRS/CFH and three (3)

CROs/AOs/NCOs. Title changes for the CRS and CRO/AO to CFH and NCO, respectively, are dependent upon NRC approval (Reference 2).

Analysis The regulatory standard for minimum staffing requirements for NRC licensees is documented in NUREG-0654. The total minimum on-shift staffing expressed in NUREG-0654, Table B-1, is ten personnel. Plant Operations shift staffing as implemented previously was based on an operating philosophy that provided defense in depth. The post-shutdown OSA concluded that in a permanently defueled condition, the on-shift SM, CRS, Radiation Protection Technician and three (3) CROs/AOs/NCOs can perform all required SEP actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. Therefore, this deviation from the guidance

BVY 14-018 / Attachment 1 / page 12 of 23 presented in NUREG-0654, Table B-1 is acceptable.

5.2.2 Major Functional Area: Notification/Communication Current Staffing Requirement STA or an AO performs the function of on-shift notification/communication.

Proposed Change Replace the STA/AO with a CRS/CFH.

Analysis This function is currently performed by an on-shift staff position (Communicator). The Communicator is either the STA or an AO.

This function is currently augmented by one position within 30 minutes and two additional positions within 60 minutes. These augmentation resources report to the EOF, assume the function once the EOF is activated and are managed by the Emergency Director (ED).

Initial notification to State authorities are required to occur within 15 minutes of declaration of an emergency and initial NRC notification is required to occur immediately after notification of the appropriate State or local agencies and not later than 60 minutes after the time of the emergency declaration. Subsequent notifications are made should the event escalate and for informational updates. The resource commitment to support the communication function is not full time so there is time to support performance of collateral duties during the first 60 minutes until staff augmentation can occur. The on-shift and off-site communicators have advanced communications capabilities available such as the InForm Notification System and the Nuclear Alert System (NAS), which permits a single telephone call to reach three states simultaneously. Communications with the NRC are over dedicated telephone lines provided for and maintained by the NRC (Emergency Notification System (ENS)). For purposes of the OSA, NRC notifications were treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it was assumed that the NRC will request an open line to be continuously maintained with the NRC Operations Center. The use of dedicated phone circuits and wireless headsets enables these notifications to be performed by the same on-shift communicator who performs the state notifications.

The SM initially approves the content of the communication with state and federal agencies until relieved of this function by the EOF. The SEP goal is to activate the EOF within 60 minutes. The EOF assumes the communication responsibility concurrent with activation.

Therefore, the current communication protocol may remain within the Control Room for the first 60 minutes, regardless of the presence of any prior ERO augmentation.

In addition, direction and control of any augmented resources, available prior to EOF activation, would need to be performed by the SM. This may represent an additional burden on the SM without commensurate benefit.

This change is acceptable because the post-shutdown OSA concluded that in a permanently defueled condition, the CRS/CFH can perform this required SEP action in a timely manner and there are no collateral duties that would prevent the timely performance of this emergency plan function.

BVY 14-018 / Attachment 1 / page 13 of 23 5.2.3 Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment: Offsite Dose Assessment Current Staffing Requirement SM, CRS, STA or Chemistry Technician performs the major task of on-shift dose assessment.

Proposed Chanqe Eliminate the STA and Chemistry Technician. The SM or CRS/CFH will perform this task.

Analysis The function of offsite dose assessment is to review radiological conditions using data from available instrumentation, assess the impact of changing radiological conditions on emergency classification, assist in accident assessment based upon those changing radiological conditions, and recommend appropriate offsite protective measures. This function is currently performed by the Control Room staff (i.e., SM, CRS, Chemistry Technician and STA). All functions and actions associated with emergency classification, accident assessment and offsite protective action measures are initially performed by on-shift resources. Classification is initially performed by the SM using procedure AP-3125, "Emergency Plan Classification and Emergency Action Level Scheme." The EAL methodology uses readily available and easily recognized plant instrumentation, and associated alarm set points combined with event and symptom based emergency action levels to determine the appropriate emergency classification. In accordance with the SEP the on-shift SM, CRS and STA have the capability to perform initial dose assessment and develop protective action recommendations.

This function is currently augmented by one person within 30 minutes. The augmentation resource reports to the EOF, assumes the function once the EOF is activated and is managed by the ED. The proposed elimination of the STA and Chemistry Technician are appropriate given the reduced risk in a permanently defueled condition. Many of the potential initiating conditions that would lead to an emergency declaration are no longer credible. The set of plant equipment required in this condition is also greatly reduced, which reduces assessments and mitigation activities in the Control Room within the first 30 minutes of an emergency.

This change is acceptable because the post-shutdown OSA concluded that in a permanently defueled condition, the CRS/CFH can perform the offsite dose assessment in a timely manner and there are no collateral duties that would prevent the timely performance of this emergency plan function. Additionally, since the post-shutdown OSA confirmed that no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events, the proposed elimination of the on-shift Chemistry Technician is acceptable.

5.2.4 Major Functional Area: Plant System Engineering 5.2.4.1 Major Task: Shift Technical Advisor Current Staffin/ Requirement

BVY 14-018 / Attachment 1 / page 14 of 23 The on-shift STA performs the major task of Shift Technical Advisor.

Proposed Change Eliminate the on-shift STA position.

Analysis The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations. They also contribute to operations during normal plant conditions. By routine monitoring of equipment and plant operations, the STA can focus on preventative actions in order to mitigate the consequences of an accident.

Because of the permanent cessation of operations and removal of fuel from the reactor vessel, the STA position is no longer necessary for technical and analytical assistance. The Technical Support function will be assumed by the remaining Control Room personnel.

The post-shutdown OSA concluded that the on-shift SM and CRS/CFH can perform any required technical analysis, until augmented by the TSC engineering staff, in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

5.2.4.2 Major Task: Core/ThermalHydraulics Current Staffinq Requirement Augment the on-shift core/thermal hydraulics capability by one within 30 minutes (Technical Support Center Reactor Engineer).

Proposed Chanqe Eliminate the Technical Support Center Reactor Engineer ERO position.

Analysis The function of this responder is to provide confirmation of adequacy of core cooling, maintenance of coolable core geometry, and to verify that actual plant response to the event is as expected. This function is initially performed by the on-shift STA under the guidance of the SM. The STA is assigned other SEP responsibilities including communication and radiological assessment functions; however, these are not considered to impact the ability of the STA to perform engineering oversight functions.

The TSC Reactor Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary in a permanently shutdown and defueled condition.

5.2.5 Major Functional Areas: Repair and Corrective Actions 5.2.5.1 Major Task: MechanicalMaintenance

BVY 14-018 / Attachment 1 / page 15 of 23 Current Staffing Requirement An AO performs the function of on-shift mechanical maintenance.

Proposed Change Replace the AO with a CRO/AO/NCO.

Analysis The function of this position is to provide for minor or limited scope damage repair and corrective actions.

The OSA defines repair and corrective action as: "An action that can be performed promptly to restore a nonfunctional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tag out controls to complete."

During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. The on-shift CROs/AOs/NCOs will have the necessary expertise and training to perform troubleshooting and minor repairs during plant operations. The CROs/AOs/NCOs would be available to satisfy any minor troubleshooting and repair activities that might be needed.

NUREG-0654, Table B-i, indicates that repair and corrective action tasks may be performed by qualified shift personnel assigned other emergency response functions/tasks.

VY Nuclear Plant Operators are trained to perform the actions associated with the repair and corrective action functional area. In addition, repair and corrective action is an acceptable collateral duty in accordance with the guidance in NEI 10-05. Therefore, the proposed change does not represent a deviation from NUREG-0654, Table B-I.

The post-shutdown OSA concluded that in a permanently defueled condition, CROs/AOs/NCOs can perform this required SEP action in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

5.2.5.2 Major Task: Rad Waste Operator Current Staffing Requirement An AO or CRO performs the function of on-shift Rad Waste Operator.

ProposedChange Replace the AO/CRO with a CRO/AO/NCO.

Analysis During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. The on-shift CRO/AOs/NCOs will have the necessary expertise and training to perform troubleshooting and minor repairs during plant operations. The CRO/AOs/NCOs would be available to satisfy any minor troubleshooting

BVY 14-018 / Attachment 1 /page 16 of 23 and repair activities that might be needed.

NUREG-0654, Table B-i, indicates that repair and corrective action tasks may be performed by qualified shift personnel assigned other emergency response functions/tasks.

VY Nuclear Plant Operators are trained to perform the actions associated with the repair and corrective action functional area. In addition, repair and corrective action is an acceptable collateral duty in accordance with the guidance in NEI 10-05. Therefore, the proposed change does not represent a deviation from NUREG-0654, Table B-I.

The post-shutdown OSA concluded that in a permanently defueled condition, AOs/NCOs can perform this required SEP action in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

5.2.5.3 Major Task: ElectricalMaintenance/Instrumentationand Control Current Staffing Requirement An AO performs the function of on-shift Electrical Maintenance/Instrumentation and Control Technician.

Proposed Chanae Replace the AO with a CRO/AO/NCO.

Analysis The function of this position is to provide for minor or limited scope damage repair and corrective actions such as identification and correction of controller and setpoint mal-adjustment, tripped breakers and overloads, surveillance necessary for accident mitigation and/or hands off troubleshooting. These are the only activities that can be accomplished in the time frame in question.

The OSA defines repair and corrective action as: "An action that can be performed promptly to restore a nonfunctional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tag out controls to complete."

During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. The on-shift CROs/AOs/NCOs will have the necessary expertise and training to perform troubleshooting and minor repairs during plant operations. The CROs/AOs/NCOs would be available to satisfy any minor troubleshooting and repair activities that might be needed.

NUREG-0654, Table B-i, indicates that repair and corrective action tasks may be performed by qualified shift personnel assigned other emergency response functions/tasks.

VY Nuclear Plant Operators are trained to perform the actions associated with the repair and corrective action functional area. In addition, repair and corrective action is an acceptable collateral duty in accordance with the guidance in NEI 10-05. Therefore, the proposed change does not represent a deviation from NUREG-0654, Table B-I.

The post-shutdown OSA concluded that in a permanently defueled condition, CROs/AOs/NCOs can perform this required SEP action in a timely manner and there are

BVY 14-018 / Attachment 1 / page 17 of 23 no collateral duties that would prevent the timely performance of this task.

5.2.6 Major Functional Area: Protective Actions (In-Plant)

Major Tasks: Access Control; RadiationProtection (RP) Coverage for Repair, Corrective Actions, Search and Rescue, FirstAid and Firefighting;PersonnelMonitoring; Dosimetry CurrentStaffing Requirement Two AOs perform the in-plant protective actions.

ProposedChange Replace the two AOs with two CROs/AOs/NCOs.

Analysis The function of these additional resources is to provide RP oversight of the on-shift complement of personnel and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, firefighting and personnel monitoring. They can also be expected to provide for access control and the issuance of dosimetry. Analysis of the proposed change for each of these tasks is discussed below. The fire brigade will continue to perform the tasks of search and rescue, first aid and firefighting in the permanently defueled condition.

5.2.6.1 Major Tasks: Access Control and PersonnelMonitoring In the original SEP, radiological access control was a labor intensive task. Dedicated RP Technicians were required to check dose margins, training qualifications, and to ensure workers had read and understood their radiation work permit. Worker access control is now automated because RP work processes have been computerized. Radiation work permit access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on their radiation work permit and to self-issue electronic dosimeters. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the radiation work permit access control system is used. If a worker's dose margin is inadequate or training is expired, the worker's access would be precluded and the access control system would not allow issuance of an electronic dosimeter. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their radiation work permit. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rate alarms. Worker use of electronic dosimeters facilitates more efficient use of RP Technicians to provide RP coverage while preserving the ALARA concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter a radiation work permit number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the radiation work permit access control computers, which allows RP Technicians to be used for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No RP involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight.

Replacing the AOs with CROs/AOs/NCOs in a permanently shutdown and defueled

BVY 14-018 / Attachment 1 / page 18 of 23 condition is supported by current access control and personnel monitoring processes and equipment.

The post-shutdown OSA concluded that in a permanently defueled condition, CROs/AOs/NCOs can perform this required SEP action in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

5.2.6.2 Major Task: RP Coverage RP coverage will only be performed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMs).

During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift RP Technician. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed ARMs (which alarm locally and remotely at preset dose rates) located throughout the plant.

5.2.6.3 Major Task: Dosimetry In the original SEP, dosimetry issuance was a manual process requiring RP Technicians to zero and issue dosimeters, verify worker training, and verify and track radiation dose margins. As addressed in the Access Control/Personnel Monitoring Section above, access control computers are now used for issue of electronic dosimetry with alarming capability.

Battery-powered electronic dosimeters are available as a backup. Worker self-issuance of electronic dosimeters has eliminated the need for RP Technicians to physically issue dosimetry, with the exception of any tasks that require specialized dosimetry and/or special body placement of the dosimetry. These types of tasks are not expected in the initial stages of an event, but during the recovery phase.

The post-shutdown OSA determined there are no time critical RP or chemistry tasks, and that task performance is directed and prioritized by the SM for the 90-minute time frame used in the analysis. There are no overlapping RP or chemistry tasks. RP tasks were able to be performed without augmented personnel in the 90-minute time frame used in the analysis.

5.2.7 Conclusion The risk of a major event resulting in the release of radiological materials to the environment is significantly reduced in the permanently defueled condition. All required radiation protection functions are accommodated within the requisite time frames using the proposed on-shift resources. Any anticipated tasks can be handled by that resource. In addition, direction and control of any 30-minute augmented resources needs to be performed by on-shift resources (i.e., the SM). This represents an additional burden on the SM without commensurate benefit.

BVY 14-018 / Attachment 1 / page 19 of 23 5.3 Summary ENO completed an evaluation of the proposed reduction in on-shift and ERO staffing and completed a post-shutdown OSA to analyze the ability of the proposed defueled on-shift and ERO organization to respond to an emergency.

The post-shutdown OSA was conducted assuming an on-shift complement of one (1) SM, one (1)

CRS/CFH, one (1) RP Technician and three (3) CROs/AOs/NCOs and indicates that the proposed on-shift personnel can satisfactorily implement all regulatory required emergency plan functions without augmented ERO personnel for at least 90 minutes following an emergency declaration.

The post-shutdown OSA confirmed that no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. Compensatory measures will be implemented to ensure that the ability to assess and declare an emergency during fuel handling activities is maintained. Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate for the permanently defueled condition.

The proposed ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The ERFs will continue to be activated at an Alert or higher declaration.

Functional responsibilities of the positions eliminated as a result of the changes described within are being reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the SEP, site commitments and regulation.

6. REGULATORY EVALUATION 6.1 Applicable Regulatory Requirements and Guidance On-Shift and ERO Staffinq The specific standard for establishing an onsite emergency organization to respond to emergency events appears in 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. Specifically:

a 10 CFR 50.47(b)(1): Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

• 10 CFR 50.47(b)(2): On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

• 10 CFR 50, Appendix E Section IV.A.1: [E-Plans must contain] A description of the normal plant operating organization.

• 10 CFR 50, Appendix E Section IV.A.2: [E-Plans must contain] A description of the onsite emergency response organization with a detailed discussion of:

• Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

BVY 14-018 / Attachment 1 / page 20 of 23

• Plant staff emergency assignments;

• Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures; NUREG-0654 (Reference 4),Section II.B, "Onsite Emergency Organization," presents guidance for meeting these requirements. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-i, "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies."

10 CFR Part 50, Appendix E, Section IV.A.9 states that licensees shall perform "...a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan."

NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants" (Reference 6) provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," is an acceptable methodology for performing the staffing analysis. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

NRC Regulatory Guide 1.101, "Emergency Response Planning and Preparedness for Nuclear Power Reactors," Revision 4 (Reference 8), Section C, stated in part "The criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1, 'Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980),' are methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans.

These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness."

Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," November 2011 (Reference 9), describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q). In Section 2.a.(1), the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes that increase the activation time of emergency response facilities.

Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1 (Reference 10) was issued by the NRC to clarify the meaning of "decrease in effectiveness" and the process for making changes to emergency plans, and to provide some examples of changes that are considered to be a decrease in effectiveness.

6.2 Precedence The requested changes to the on-shift staffing and ERO staffing are similar in nature to the post-shutdown changes implemented by Kewaunee Power Station, using the 10 CFR 50.54(q) process that resulted in the NRC issuing a Severity Level IVviolation (Reference 11). As a result of this violation, ENO is submitting the proposed changes as a License Amendment Request pursuant to 10 CFR 50.54(q)(4) and 10 CFR. 50.90.

BVY 14-018 / Attachment 1 / page 21 of 23 6.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.92, Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the Vermont Yankee Nuclear Power Station (VY) Site Emergency Plan (SEP) to reduce the number of on-shift and emergency response organization (ERO) positions commensurate with the hazards associated with a permanently shutdown and defueled facility.

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

1. Does the prooosed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to the SEP do not impact the function of plant structures, systems, or components (SSCs). The proposed changes do not affect accident initiators or precursors, nor does it alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and ERO to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition. The proposed changes only remove positions that will no longer be credited in the SEP in the permanently defueled condition.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes reduce the number of on-shift and ERO positions commensurate with the hazards associated with a permanently shutdown and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also, the proposed changes do not result in a change to the way that the equipment or facility is operated so that no new accident initiators are created.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

BVY 14-018 / Attachment 1 / page 22 of 23 Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the SEP staffing and do not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes. The revised SEP will continue to provide the necessary response staff with the proposed changes.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

6.4 Environmental Considerations This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described in Section 6.3 of this evaluation, the proposed changes involve no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, ENO concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

7. REFERENCES

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, 'Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and

BVY 14-018 / Attachment 1 / page 23 of 23 Technical Specification Administrative Controls for Permanently Defueled Condition," BVY 13-096, dated October 31, 2013 (ML13316A004)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC "Request for Approval of Certified Fuel Handler Training Program," BVY 13-095, dated October 31, 2013 (ML13325B015)

4. NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, published November 1980.

5. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, "Enhancements to Emergency Preparedness Regulations; Final Rule."

6. NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants," Revision 0, November 2011 (ML113010523)

7. NEI 10-05, Rev. 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities."

8. NRC Regulatory Guide 1.101, "Emergency Response Planning and Preparedness for Nuclear Power Reactors," Revision 4, July 2003

9. Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," November 2011

10. Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1, April 19, 2011

11. Letter, USNRC to Dominion Energy Kewaunee, Inc., "NRC Inspection Report No.

05000305/2013011 (DNMS)-Kewaunee Power Station," dated March 10, 2014 (ML14069A225)

BVY 14-018 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Tabular Summary of Proposed Changes to Site Emergency Plan

Emergency Plan Section Before (Rev. 54) After Reason for Change Table of Contents Updated page numbers as necessary Editorial revision to reflect changes described below.

Table of Contents - List of Figures Figure 8.1 Normal On-Shift Figure 8.1 Defueled On-Shift VY will no longer be an operating Emergency Organization Emergency Organization nuclear power plant. The title change reflects the permanently defueled organizational structure.

Table of Contents - List of Figures Figure 8.2 Vermont Yankee Figure 8.2 Vermont Yankee VY will no longer be an operating Emergency Management Organization Defueled Emergency Management nuclear power plant. The title Organization change reflects the permanently defueled organizational structure.

Table of Contents - List of Figures Figure 8.3 Technical Support Figure 8.3 Defueled Technical VY will no longer be an operating Center Emergency Organization Support Center Emergency nuclear power plant. The title Organization change reflects the permanently defueled organizational structure.

Table of Contents - List of Figures Figure 8.4 Operations Support (Deleted) ERO Staffing changes result in one Center Emergency Organization remaining OSC position (OSC Manager) illustrated on the figure.

A figure is no longer necessary to describe the OSC organization.

Table of Contents - List of Figures Figure 8.5 Emergency Figure 8.5 Defueled Emergency VY will no longer be an operating Operations Facility Organization Operations Facility Organization nuclear power plant. The title change reflects the permanently defueled organizational structure.

Table of Contents - List of Figures Figure 8.7 Joint Information Figure 8.7 Defueled Joint VY will no longer be an operating Center Organization Information Center Organization nuclear power plant. The title change reflects the permanently defueled organizational structure.

Section 4.1 Vermont Yankee Nuclear Power Station Vermont Yankee Nuclear Power Station VY will no longer be an operating is located on the west bank of the is located on the west bank of the nuclear power plant. The Site Connecticut River immediately Connecticut River immediately Description has been revised to upstream of the Vernon Hydrostation, upstream of the Vernon Hydrostation, indicate the permanently shutdown in the town of Vernon, Vermont. The in the town of Vernon, Vermont. The 1 of 19

Emergency Plan Section Before (Rev. 54)

Vermont Yankee Nuclear Power Station

{ After Vermont Yankee Nuclear Power Station I Reason for Change and defueled condition.

is a boiling water reactor having a ceased power operations and is thermal rated power of 1912 MWt. permanently defueled in accordance The station, shown in Figure 4.1, is with 10 CFR 50.82(a)(1)(i) and (ii). The located on about 125 acres in station, shown in Figure 4.1, is located Windham County, and is owned by on about 125 acres in Windham Entergy, with the exception of a County, and is owned by Entergy, with narrow strip of land between the the exception of a narrow strip of land Connecticut River and the Vermont between the Connecticut River and the Yankee property for which it has Vermont Yankee property for which it perpetual rights and easements from has perpetual rights and easements the owner, New England Power from the owner, New England Power Company. Company.

On September 23, 2013, ENO submitted a notification of permanent cessation of power operations pursuant to 10 CFR 50.82(a)(1)(i), stating that ENO has decided to permanently cease power operation of Vermont Yankee in the fourth quarter of 2014. ENO has submitted written certification to the NRC, in accordance with 10 CFR 50.82(a)(1) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel. Upon docketing of these certifications, the 10 CFR Part 50 license for VY no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

With irradiated fuel being stored in the Spent Fuel Pool and the ISFSI, the 2 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change reactor, reactor coolant system and secondary system are no longer in operation and have no function related to the storage of the irradiated fuel.

Therefore, the postulated accidents involving failure or malfunction of the reactor and reactor coolant system or secondary system are no longer applicable.

Section 4.2 - 2fna Paragraph The nearest house is 1,300 feet from The nearest house is 1,300 feet from Editorial. The Hinsdale Raceway no the Reactor Building and is one of the Reactor Building and is one of longer operates and reference is several west of the site. The Vernon several west of the site. The Vernon removed from the Emergency Plan.

Elementary School (approximate Elementary School (approximate enrollment of 250 pupils) is about enrollment of 250 pupils) is about 1,500 feet from the Reactor Building. 1,500 feet from the Reactor Building.

The nearest hospital, Brattleboro The nearest hospital, Brattleboro Memorial, is approximately five (5) Memorial, is approximately five (5) miles north-northwest from the site. miles north-northwest from the site.

The nearest dairy farm is The nearest dairy farm is approximately approximately 1/2-mile northwest of 1/2-mile northwest of the site.

the site. Additional dairy farms are Additional dairy farms are located located within a 5-mile radius of the within a 5-mile radius of the plant. A plant. The largest sports facility in the nursing home is located 2 miles south vicinity is the Hinsdale Raceway, of the plant. These areas have been located approximately three (3) miles noted since they have required special from the site. For racing events, the planning consideration by offsite average attendance is approximately authorities in the event of a 4,000. A nursing home is located 2 radiological emergency at Vermont miles south of the plant. These areas Yankee.

have been noted since they have required special planning consideration by offsite authorities in the event of a radiological emergency at Vermont Yankee.

3 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change Section 8.1 - 2na Paragraph During normal operations, the The minimum staff on duty at the plant VY will no longer be an operating minimum staff on duty at the plant during all shifts consists of one (1) Shift nuclear power plant. The following during all shifts consists of one (1) Shift Manager, one (1) Control Room on-shift positions will be Manager, one (1) Control Room Supervisor (CRS)/Certified Fuel Handler eliminated:

Supervisor, two (2) Control Room (CFH), three (3) Auxiliary Operators

• Shift Technical Advisor (STA)

Operators, six (6) Auxiliary Operators, (AO)/Control Room Operators

" Two (2) Control Room one (1) Shift Technical Advisor, one (1) (CRO)/Non-Certified Operators (NCO),

Operators Radiation Protection Technician, one one (1) Radiation Protection Technician

• Three (3) Auxiliary Operators (1) Chemistry Technician and security and security personnel as indicated in

• Chemistry Technician personnel as indicated in Figure 8.1. Figure 8.1. The responsibility for The responsibility for determining the determining the status of the plant in Following permanent cessation of status of the plant in an emergency is an emergency is assigned to the Shift operations and removal of fuel assigned to the Shift Manager or, in his Manager or, in his absence from the from the reactor vessel, Operations absence from the Control Room, to the Control Room, to the Control Room on-shift personnel will consist of Control Room Supervisor who has the Supervisor who has the authority and one (1) Shift Manager (SM), one (1) authority and responsibility to responsibility to immediately initiate Control Room Supervisor immediately initiate any emergency any emergency actions, including (CRS)/Certified Fuel Handler (CFH) actions, including emergency emergency classification and and three (3) Auxiliary Operators classification and notification. notification. Additional personnel are (AOs)/Control Room Operators Additional personnel are available on available on an on-call basis to respond (CROs)/Non-Certified Operators an on-call basis to respond to plant to plant emergencies. Corrective (NCOs). Title changes for the CRS to emergencies. Corrective action and action and repair, as outlined in CFH and the AO and CRO to NCO repair, as outlined in Table 8.4, is Table 8.4, is performed by Operations are dependent upon NRC approval performed by Operations staff on-shift staff on-shift until supplemented by of proposed changes to the VY until supplemented by additional ERO additional ERO staff. Technical Specifications that staff. replace references to licensed and non-licensed operators with references to CFHs and NCOs.

These staffing levels have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently 4 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change defueled condition.

Section 8.2.2 - 1St Paragraph, Item 5. Develop guidance for plant shift 5. Develop guidance for plant shift VY will no longer be an operating 5 operations concerning plant protection operations concerning plant protection; nuclear power plant and of the reactor core; emplacement or retention of fuel into the reactor vessel will no longer be authorized. Therefore, the need for the Emergency Plant Manager's responsibilities to include protection of the reactor core is no longer applicable.

Section 8.2.2 - 2 nd Paragraph A qualified manager assumes the role A qualified manager assumes the role VY will no longer be an operating of Emergency Plant Manager under all of Emergency Plant Manager under all nuclear power plant and emergency conditions. To assist the emergency conditions. To assist the emplacement or retention of fuel Emergency Plant Manager, the TSC is Emergency Plant Manager, the TSC is into the reactor vessel will no staffed by representatives from the staffed by representatives from the longer be authorized. Therefore, following departments as depicted in following departments as depicted in the need to maintain a Reactor Figure 8.3: Figure 8.3: Engineer in the TSC is no longer 0 Operations applicable.

• Operations

• Maintenance

• Maintenance

• Reactor Engineering

• Engineering

• Engineering 0 Chemistry

• Chemistry (in the OSC)

• Radiation Protection

• Radiation Protection

• Security (stationed at the off

• Security (stationed at the off site command post) site command post)

Table 8.3, Page 3 of 3 The Public Information Liaison at the The Technical Advisor at the EOF/RC The position of Public Information EOF/RC relays accident status reports relays accident status reports to the Liaison will not exist in the to the Joint Information Center. Joint Information Center. Permanently Defueled Emergency Response Organization (ERO).

Duties and responsibilities will be 5 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change transferred to the Technical Advisor position.

Table 8.4 - Page 1 of 2, Functional Area - Plant Operations &

Assessment of Operational Aspects Shift Manager (I)

CRS (1)

CRO (2)

AO (6)

On Shift On Shift On Shift On Shift i

Shift Mana*er (1)

CRSICeftifiedFuet Handlet (CFHr ..

AOICRONCO-M

............ i-i I

1 On Shift I3 On Shift On Shift I .........

I i

VY will no longer be an operating nuclear power plant. The following on-shift positions will be STA (1) On Shift eliminated:

• STA

• Two (2) Control Room Operators

" Three (3) Auxiliary Operators

• Chemistry Technician Following permanent cessation of operations and removal of fuel from the reactor vessel, Operations on-shift personnel will consist of the SM, one (1) CRS/ CFH and three (3) AOs/CROs/NCOs. Title changes for the CRS to CFH and AO and CRO to NCO are dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

These staffing levels have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

STA oversight and technical knowledge in this functional area 6 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change will be transferred to the Shift Manager and/or the CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents previously submitted to the NRC.

Table 8.4- Page 1 of 2; Functional STA/AO On Shft CRS/CFH OnShift VY will no longer be an operating Area A(1) nuclear position power will be plant. The STA

- STA/Offsdte 3 oVENS.mb=iJe*;b 30 nm.

60 min. Offsite ComENS Comm (1)' 30 min.

offsi~t*cOMMIEscommr(2) 60mi eliminated.

Notification/Communication; Major STAfOffsite fsnnJENS C4='b0om*1o positionwillbeeliminated.

Tasks - Notify Licensee, State, local Following permanent cessation of and federal personnel & maintain communicationoprtosthCemty operations, the Chemistry Technician Position will not be responsible for performing notification/communications tasks.

STA assignments in this functional area will be transferred to a CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Title change for the CRS to CFH is dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

7 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4 - Page 1 of 2; Functional EOF Emergency Director (1) 60 min. EOF Emergency Orector*(1) 60 min VY will no longer be an operating Area - Radiological Accident Shift "CRSISTA/NQ Tech On Shift Shi ft/ ICSI/CFH On Shift nuclear power plant. The STA and Assessment and Support of RStaff(1), 30 mm. RP Staff (1)- 30. on-shift Chemistry Tech positions Operational Accident Assessment; will be eliminated.

Major Tasks -Offsite Dose STA assignments in this functional Assessment area will be transferred to the Shift Manager and/or the Control Room Supervisor. This transfer of duties and removal of the on-shift Chemistry Tech position have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Title changes for the CRS to CFH is dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

Table 8.4 - Page I of 2; Functional ShiftChem. Tech (1) On Shift 6m. VY will no longer be an operating Area - Radiological Accident Chem staff() 60 min. nuclear power plant. The on-shift Assessment and Support of Chemistry Tech position will be Operational Accident Assessment; eliminated.

Major Tasks - Removal of the on-shift Chemistry Chemistry/Radiochemistry Tech position has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled 8 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change condition.

Table 8.4 - Page 1 of 2; Functional STA (1 On Shiftl PosonsnoteededinaPermanently VY will no longer be an operating Area - Plant System Engineering; Tsc RE (1) 30 mi,. Ofueled Conddion nuclear power plant. The STA Major Tasks - Shift Technical position will be eliminated.

Advisor and Core Thermal STA oversight and technical Hydraulics knowledge in this functional area will be transferred to the Shift Manager and/or the CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Additionally, the need to maintain a Reactor Engineer in the TSC is no longer applicable.

Table 8.4 - Page 1of 2; Functional __________________________

AO_(I-)_IOnShifthift__on _ The Defueled Organization contains Area - Repair & Corrective Actions; three (3) AOs/CROs/NCOs on-shift.

Major Tasks - Mechanical This on-shift complement has been Maintenance evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Title change for the AO and CRO to NCO is dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with 9 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change references to CFHs and NCOs.

Table 8.4 - Page 1 of 2; Functional I__o, ___5____ 16__ran. __A__CO ____O__________. The CRO position is eliminated in Area - Repair & Corrective Actions; 1 (1) 60 AOCRONGO the post-shutdown condition. The Major Tasks - Rad Waste Operator Defueled Organization consists of three (3) AOs/CROs/NCOs on-shift.

This on-shift complement has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Title change for the AO and CRO to NCO is dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

Table 8.4- Page 1 of 2; Functional rShifAO(1) Oh Shi7 SNftAO/CRO,1'CO(") On SNft The Defueled Organization consists Area - Repair & Corrective Actions; Maintenance (1) 30 . Mintenance (1) 30 mi. of three (3) AOs/CROs/NCOs on-Major Tasks- Electrical Maintenance (1) 6Oniin. Maintenance (1) 60 m shift. This on-shift complement has Maintenance/Instrumentation & been evaluated in the VY analysis of Control Technician proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Title change for the AO and CRO to NCO is dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and 10 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change non-licensed operators with references to CFHs and NCOs.

Table 8.4 - Page 2 of 2; Functional Shif AO (2- 2 On Shift ShiftAOiCRORINCO(2-)2 On Shift The Defueled Organization consists Area - Protective Actions (In Plant); RP(2) 30 mnn RP(2) 30 of three (3) AOs/CROs/NCOs on-Major Tasks - Radiation Protection, RP (2) shift. This on-shift complement has access control, HP, coverage for been evaluated in the VY analysis of repair, corrective actions, search & proposed post-shutdown on-shift rescue, first aid & firefighting, staffing in conjunction with the personnel monitoring, dosimetry postulated accidents that will be applicable in the permanently defueled condition.

Title change for the AO and CRO to NCO is dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

Table 8.4, Note **** May be performed by engineering aide Title Change is dependent on NRC VY will no longer be an operating to Shift Manager (STA for ENVY) approval of revised Technical nuclear power plant. The STA Specifications (BVY 13-096, dated position will be eliminated. STA 10/31/13). CFHs will supervise fuel oversight and technical knowledge handling operations in the permanently will be transferred to the Shift defueled condition. The CRS and SM Manager and/or the CRS/CFH. This will be qualified as CFHs. However, the transfer of duties has been SM requires additional qualification evaluated in the VY analysis of beyond the CFH training. Therefore, proposed post-shutdown on-shift any reference to the CFH position staffing in conjunction with the throughout this Plan is considered to postulated accidents that will be be equivalent to the CRS position. Non- applicable in the permanently Certified Operators will perform duties defueled condition.

typically associated with those Title changes for the CRS to CFH performed by Auxiliary Operators and and AO and CR0 to NCO are Control Room Operators, such as 11 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change manipulation and monitoring of plant dependent upon NRC approval of equipment. proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

Table 8.4, Note 1 AP 0894 specifies minimum shift AP 0894 specifies minimum shift The Defueled on-shift staffing has staffing requirements. FB requires S staffing requirements. FB requires 5 been evaluated in the VY analysis of persons per TRM and the Vermont persons per TRM and the Vermont proposed post-shutdown on-shift Yankee Nuclear Power Station On-Shift Yankee Nuclear Power Station Analysis staffing in conjunction with the Staffing Analysis. The staffing analysis of Proposed Post-Shutdown On-Shift postulated accidents that will be is maintained as a controlled document Staffing. The staffing analysis was applicable in the permanently and is effective 30 days after OSRC evaluated to reflect VY's permanently defueled condition.

approval. STA and Chemistry Tech shutdown and defueled conditions, must be available within 10 minutes to including the on-shift staff composition the Control Room. VY letter to NRC and revised accident analyses.

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 III.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.

Table 8.4, Note 2 All AOs use digital dosimeters with All AOs/CROs/NCOs use digital Title change for the AOs and CROs features for dose rate and total dose dosimeters with features for dose rate to NCO is dependent upon NRC monitoring. AOs are trained to self- and total dose monitoring, approval of proposed changes to monitor in an emergency. AOs/CROs/NCOs are trained to self- the VY Technical Specifications that monitor in an emergency. replace references to licensed and non-licensed operators with 12 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change references to CFHs and NCOs.

Table 8.4, Note 3 ENVY has designated pager holders ENVY has designated ERO members The Defueled Organization will who staff positions required to meet who staff positions required to meet consist of fewer than 4 teams minimum staffing to activate TSC, OSC minimum staffing to activate the TSC, rotating ERO duty.

and EOF (see E Plan Figures 8.3 through OSC and EOF. The minimum staff 8.5). There are a minimum of 4 positions required to activate the TSC Aditial to this noe ar persons per position (4 teams who and EOF are shown in E Plan Figures 8.3 editrial to r ovrerst rotate duty). However, all persons on and 8.5. The OSC Manager is the only pagers and pager holders.

teams are expected to respond. In position required to activate and staff addition, all other ERO personnel not the OSC. All ERO personnel are on pagers are notified by the expected to respond when notified by emergency call-in notification system the emergency call-in notification and are expected to respond. system.

Table 8.4, Note 4 The on-shift Shift Manager, CRS, STA, The on-shift Shift Manager and CRS VY will no longer be an operating and Chem Tech have the capability to have the capability to do initial dose nuclear power plant. The STA and do initial dose assessment and PAR. assessment and PAR. The TSC and EOF on-shift Chemistry Technician The TSC and EOF radiation assessment radiation assessment staff relieves positions will be eliminated.

staff relieves them of this function. them of this function.

Figure 8.1 Normal On-Shift Emergency Replaced figure with "Defueled On- VY will no longer be an operating Organization Shift Emergency Organization" figure. nuclear power plant. The following on-shift positions will be Deleted the following positions: eliminated:

• Shift Technical Advisor

• STA

• Chem Tech C Two (2) Control Room

• Control Room Operators Operators Replaced "Auxiliary Operators" with 0 Three (3) Auxiliary Operators "AOs/CROs/NCOs" 0 Chemistry Technician Following permanent cessation of operations and removal of fuel from the reactor vessel, Operations on-shift personnel will consist of the (SM, one (1) CRS/ CFH and three (3) AOs/CROs/NCOs. Title 13 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change changes for the CRS to CFH and AO and CRO to NCO are dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

These staffing levels have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

STA oversight and technical knowledge in this functional area will be transferred to the Shift Manager and/or the CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents previously submitted to the NRC.

Figure 8.2 VY Emergency Management Replaced figure with "VY Defueled The positions of EOF Manager and Organization Emergency Management Organization" TSC Manager will not exist in the Permanently Defueled ERO. Duties Deleted the following positions: adrsosblte ilb be and responsibilities will

• EOF Manager transferred to remaining positions

• TSC Manager within each Emergency Response Facility.

Figure 8.3 Technical Support Center Emergency Replaced figure with "Defueled The TSC positions identified for 14 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change Organization Technical Support Center Emergency deletion will not exist in the Organization" Permanently Defueled ERO. Duties Deleted the following positions: and responsibilities will be transferred to remaining positions

• TSC Manager within the TSC.

• TSC Communicator

• Mechanical Engineer

• Reactor Engineer

• Electrical /I&C Engineers

• IT Specialist Figure 8.4 Operations Support Center Emergency Deleted figure ERO Staffing changes result in one Organization remaining OSC position (OSC Manager) - A figure is no longer necessary to describe the OSC organization.

Figure 8.5 Emergency Operations Facility Replaced figure with "Defueled The EOF positions identified for Organization Emergency Operations Facility deletion will not exist in the Organization" Permanently Defueled ERO. Duties Deleted the following positions: and responsibilities will be transferred to remaining positions

" EOF Manager within the EOF.

• EOF Communicator

• Public Information Liaison

• EOF Log Keeper

• IT Specialist Figure 8.7 Joint Information Center Organization Replaced figure with "Defueled Joint The JIC positions identified for Information Center Organization" deletion will not exist in the Deleted the following positions: Permanently Defueled ERO. Duties and responsibilities will be

• Information Coordinator transferred to remaining positions

• Technical Assistant within the JIC.

• Credentialing

• Press Release Writer 15 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change

• Logistics Coordinator

" Inquiry Response Coordinator

• JIC Log Keeper Section 9.2.1 - 2 d Paragraph 3. The Shift Technical Advisor reports Deleted VY will no longer be an operating to the Control Room and provides nuclear power plant. The STA technical support as necessary; position will be eliminated.

STA assignments in this functional area will be transferred to a CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Section 9.3 - 3 rd Paragraph De-escalation from a Notification of De-escalation from a Notification of VY will no longer be an operating Unusual Event to a recovery phase Unusual Event to a recovery phase nuclear power plant and requires satisfying the following requires satisfying the following emplacement or retention of fuel criteria: criteria: into the reactor vessel will no

1. Criticality controls are in effect; 1. Criticality controls are in effect; longer be authorized. Therefore, the need for adequate core cooling,

2. The core is being adequately 2. The fission product release has control over containment pressure cooled; been controlled; and temperature and control of

3. The fission product release has 3. An adequate heat transfer path to reactor coolant system pressure is an ultimate heat sink has been not necessary.

been controlled; established;

4. Control has been established over containment pressure and 4. Notification of Unusual Event temperature; conditions have been reviewed, are under control, and are not An adequate heat transfer path to e e toder io re fut 5.

an ultimate heat sink has been expected to deteriorate further.

established;

6. Reactor coolant system pressure is 16 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change under control; and/or

7. Notification of Unusual Event conditions have been reviewed, are under control, and are not expected to deteriorate further.

Table 9.1, Technical Support Emergency Plant Manager Emergency Plant Manager The TSC positions identified for Center; Alert or Site Area TSC Manager Maintenance Coordinator deletion will not exist in the Emergency or General Emergency (Electrical/Mechanical/l&C) Permanently Defueled ERO. Duties Column Maintenance Coordinator and responsibilities will be (Electrical/Mechanical/l&C) Radiological Coordinator transferred to remaining positions Engineering Coordinator(Project, within the TSC.

Radiological Coordinator Reactor Engineer System, Design)

Engineering Coordinator(Project, Operations Coordinator System, Design)

Operations Coordinator Engineering Support Group Table 9.1, Operations Support OSC Manager OSC Manager VY will no longer be an operating Center; Alert or Site Area Radiation Protection Staff Radiation Protection Staff nuclear power plant. Use of the Emergency or General Emergency term "licensed" is no longer Chemistry Staff Chemistry Staff appropriate.

Spare Licensed Operators Spare AOs/CROs/NCOs The OSC positions identified for Spare Auxiliary Operators Control Instrument Specialists deletion will not exist in the Permanently Defueled ERO. Duties Control Instrument Specialists Plant Mechanics and responsibilities will be Plant Mechanics transferred to remaining positions within the OSC.

Table 9.1, Emergency Operations Emergency Director Emergency Director The EOF positions identified for Facility/Recovery Center; Alert or Offsite Communicator Offsite Communicator deletion will not exist in the Site Area Emergency or General Permanently Defueled ERO. Duties Emergency Column Technical Advisor Technical Advisor and responsibilities will be transferred to remaining positions 17 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change EOF Manager Administration and Logistics within the EOF.

Administration and Logistics Coordinator Coordinator Radiological Assessment Coordinator Radiological Assessment Coordinator *Site/Offsite Monitoring Teams Personnel & Equipment Monitor

• Site/Offsite Monitoring Teams Public Information Liaison Table 9.1, Joint Information Center; Company Spokesperson Company Spokesperson The JIC positions identified for Alert or Site Area Emergency or VY Public Information Staff deletion will not exist in the General Emergency Permanently Defueled ERO. Duties Nuclear Public Information and responsibilities will be Representatives transferred to remaining positions within the JIC.

Joint Information Center Staff Section 10.2 - Ist Paragraph In the event a General Emergency has In the event a General Emergency has VY will no longer be an operating been declared, Vermont Yankee been declared, Vermont Yankee nuclear power plant and immediately recommends protective immediately recommends protective emplacement or retention of fuel actions to state authorities based on actions to state authorities based on into the reactor vessel will no plant conditions which include the plant conditions. At a minimum, the longer be authorized. Therefore, status of core and containment Shift Manager or Emergency Director, the need to communicate the conditions. At a minimum, the Shift who is in charge of the emergency status of the core and containment Manager or Emergency Director, who response activities, recommends that conditions is not necessary.

is in charge of the emergency response the general public be advised to seek activities, recommends that the shelter for the towns of Hinsdale, New general public be advised to seek Hampshire and Vernon, Vermont; and shelter for the towns of Hinsdale, New the towns located five miles downwind Hampshire and Vernon, Vermont; and in the affected sectors.

the towns located five miles downwind in the affected sectors.

Section 10.2 - 2nd Paragraph If plant conditions indicate a severe If plant conditions indicate a severe VY will no longer be an operating reactor accident exists involving actual accident exists, Vermont Yankee nuclear power plant and I or projected substantial core damage, recommends to the appropriate state emplacement or retention of fuel 18 of 19

Emergency Plan Section Before (Rev. 54) After Reason for Change Vermont Yankee recommends to the officials evacuation of the towns of into the reactor vessel will no appropriate state officials evacuation Hinsdale, New Hampshire and Vernon, longer be authorized. Therefore, an of the towns of Hinsdale, New Vermont; and all towns located five accident involving the reactor the Hampshire and Vernon, Vermont; and miles downwind in the affected potential for actual or projected all towns located five miles downwind sectors. substantial core damage no longer in the affected sectors. exists.

Section 10.3 - 2nd Paragraph Table 10.2 specifies the guidelines on Table 10.2 specifies the guidelines on VY will no longer be an operating emergency dose limits for personnel emergency dose limits for personnel nuclear power plant. The on-shift providing emergency response duties providing emergency response duties Chemistry Technician positions will which is consistent with the which is consistent with the be eliminated.

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

Section 11.3 - 4th Paragraph The Public Information Liaison and The Technical Advisor and required The Technical Advisor will assume required staff report to the EOF/RC for staff report to the EOF/RC for this duty in the permanently coordinating the accident information coordinating the accident information defueled condition.

between the plant and the Joint between the plant and the Joint Information Center. Information Center.

19 of 19

BVY 14-018 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Proposed Revision to Site Emergency Plan Pages

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 Neoal Defueled On-Shift Emergency Organization Figure 8.2 Vermont Yankee Defueled Emergency Management Organization Figure 8.3 Defueled Technical Support Center Emergency Organization Figure 8.4 Opc.ations

,-nterSuppor EFmergencY . ,ganization(Deleted)

Figure 8.5 Defueled Emergency Operations Facility Organization Figure 8.6 (Deleted)

Figure 8.7 Defueled Joint Information Center Organization Emergency Plan Revision 64PENDING 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 64PENDING Table of Contents Page vii of vii Entergy Vermont Yankee

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 reaGcer having a thermal rated power of 1912 MWtceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). 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.

On September 23, 2013, ENO submitted a notification of permanent cessation of power operations pursuant to 10 CFR 50.82(a)(1)(i), stating that ENO has decided to permanently cease power operation of Vermont Yankee in the fourth quarter of 2014. ENO has submitted written certification to the NRC, in accordance with 10 CFR 50.82(a)(1) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel. Upon docketing of these certifications, the 10 CFR Part 50 license for VY no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

With irradiated fuel being stored in the Spent Fuel Pool and the ISFSI, the reactor, reactor coolant system and secondary system are no longer in operation and have no function related to the storage of the irradiated fuel. Therefore, the postulated accidents involving failure or malfunction of the reactor and reactor coolant system or secondary system are no longer applicable.

4.2. Area Characteristics, Land Use and Demography 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 Emergency Plan Revision ,54PENDING Page 10 of 125 Entergy Vermont Yankee

5-mile radius of the plant. The larg.st sports facility in the vicinity is the HInsdalc Ra..way, locGated approximately three (3) miles from the site. Fo rain cyents, the average attendan ,is,...mat.ly 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.

Emergency Plan Revision -54PENDING Page 11 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.

DUrn"g normal opeatn"*,, tThe minimum staff on duty at the plant during all shifts consists of one (1) Shift Manager, one (1) Control Room Supervisor (CRS)/Certified Fuel Handler (CFH), three (3) Auxiliary Operators (AO)/Control Room Operators (CRO)/Non-Certified Operators (NCO) (2) ,.,4., Room .. , ,.... ,sox (6) Auxiliary O,'- , one (!) 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 54PENDING Page 47 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-ef4the reaGteG*=e-,;

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 RcactOF EnginoRin

• Engineering

• Chemistry (OR the-*QS4.v

• Radiation Protection

• Security (stationed at the off site command post)

Emergency Plan Revision 54PENDING Page 51 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 Technical Advisor PUbliG State press personnel coordinate Information Liaison at the EOF/RC releases with the Company relays accident status reports to the Spokesperson.

Joint Information Center.

The Company Spokesperson releases the information to the media.

Emergency Plan Revision 64PENDING Page 63 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/Certified Fuel Handler (CFH).. (1) On Shift Operational Aspects _ _Shif-t A,6-6AO/CRO/NCO.... (3) On Shift

&TA4144OShf Emergency Direction Shift Manager (1"*) On Shift

& Control (Emergency Coordinator)***

Notification / Notify Licensee, State STA/ AOCRS/CFH On Shift Communication"". local and federal ST-A/Offsite Comm/ENS Comm/Ghem--TeGh 30 min.

personnel & maintain (1) 3 60 min.

communication ST-A-Offsite Comm/ENS Comm/ChenTeGh (2) 3 Radiological Emergency Operations EOF Emergency Director (1) 60 min.

Accident Facility (EOF) Director Shift Mgr_/CRS/CFH/STNChem Th 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/ Shift Chem. Tech (1) OF; qShft60 Radiochemistry Chem staff (1) min.

Plant System Shift Technical Advisor Positions not needed in a Permanently Engineering Core/Thermal hydraulics Defueled ConditionST-A-(4ý T4S, ;-1E--14\-2 Electrical TSC Manager/TSC Engineering staff (1) 60 min.

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

Repair & Corrective Mechanical Maintenance Sh4t-AOShift AO/CRO/NCO-(I**) On Shift Actions Mechanical Maintenance Maintenance (1) 60 min.

Rad Waste operator AQ/0R0444AO/CRO/NCO 60 min.

Electrical Maintenance / Sh4t-AOShift AO/CRO/NCO-(1**) On Shift Instrumentation & Control Maintenance (1) 30 min.

Technician Maintenance (1) 60 min.

Instrumentation & Control Maintenance (1) 30 min.

Technician Emergency Plan Revision 54PENDING Page 64 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 1 RESPONSE AREA TIME Protective Actions Radiation protection, Shift AO/CRO/NCO-(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.

Title Change is dependent on NRC approval of revised Technical Specifications (BVY 13-096, dated 10/31/13). CFHs will supervise fuel handling operations in the permanently defueled condition. The CRS and SM will be qualified as CFHs. However, the SM requires additional qualification beyond the CFH training. Therefore, any reference to the CFH position throughout this Plan is considered to be equivalent to the CRS position. Non-Certified Operators will perform duties typically associated with those performed by Auxiliary Operators and Control Room Operators, such as manipulation and monitoring of plant equipment.May be perfor.med by engineering aide to Shift Manager (STA for NOTES

1. AP 0894 specifies minimum shift staffing requirements. FB requires 5 persons per TRM and the Vermont Yankee Nuclear Power Station Analysis of Proposed Post-Shutdown On-Shift Staffing Aalysis. The staffing analysis was evaluated to reflect VY's permanently shutdown and defueled

-nnditinng int-lh linn the nn-*hift staff r~nrnnn~zitinn qnri rovicar nt-r'irtnt *nnn h acTh ýnfa analysis is maintained as a controlled document and is effective 30 days after OSRO approeval.

STA and Chemistry Tech must be available within 10 mlinutes; to- the Control ROom". VY, letter to NIRC d-ated- 4A1 41 981 (F=VY 81 65) establ-Ihin positin. VY letter: to NRC 6/22/1982 (FYVY 82

75) Supplement NUREG 0737 item 11I.A.A.I'2 on training of on shift staff to support position for staffing. VY letter to NRC 1/11/1981AR (F=VY 81 65) T-MI Action Plan Item 111A.1 .2, goal for augmentation of staff. %a4letter to NRC 6/15/82 (F=VY 82 7-0) Results of Augmentation drills to support use of qoals. Titles of EINVY FRO positions are shown.

2. All AOs/CROs/NCOs use digital dosimeters with features for dose rate and total dose monitoring.

AOs/CROs/NCOs are trained to self-monitor in an emergency.

Emergency Plan Revision 64PENDING Page 65 of 125 Entergy Vermont Yankee

3. ENVY has designated pae,-heIF ersERO members who staff positions required to meet minimum staffing to activate the TSC, OSC and EOF. The minimum staff positions required to activate the TSC and EOF are (shown in see E Plan Figures 8.3 thr and 8.5-. The OSC Manaqer is the only position required to activate and staff the OSC. There are *,e,,*R a M... MUM of 4 per In pcsition (4 toame who rotate duty). However, all percons on teams are expected to respond.

add~iepn-,aAll ether-ERO personnel .* OR-pageIs-are expected to respond when notified by the emergency call-in notification system and a*re expected to rocpond.

4. The on-shift Shift Managers- and CRS, STA, and Chem Tcch 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 64PENDING Page 66 of 125 Entergy Vermont Yankee

I

---

i Security II -I -I Auxiliary Operator/

Control Room Operator/

Non-Certified fOnpritnr* [3]

• Title change is dependent on NRC approval of Note:

revised Technical Specifications. Corrective action repair is performed by Operations Staff on-shift until

• • May be provided by shift personnel assigned other supplemented by emergency response functions. Fire Brigade positions are staffed in organLzation.

accordance with Technical Requirements Manual and Administrative procedures.

fx] = Number of Individuals Figure 8.1 Defueled On-shift Emergency Organization.

Emergency Plan Revision PENDING Page 65 of 125 Entergy Vermont Yankee

Figure 8.2 VY Defueled Emergency Management Organization Emergency Plan Revision PENDING Page 66 of 125 Entergy Vermont Yankee

Mainenace Raiolgicl Eginerig OpratonsSecurity ENS Communicator MieaneEineigRdoocaOpatnsCoordinator Coordinator* Coordinator* Coordinator Coordinator* (incident

• required for activation Figure 8.3 Defueled Technical Support Center Emergency Organization Emergency Plan Revision PENDING Page 67 of 125 Entergy Vermont Yankee

Dose Assessment Team required for activalion Figure 8.5 Defueled Emergency Operations Facility Organization Emergency Plan Revision PENDING Page 68 of 125 Entergy Vermont Yankee

• required for activation Figure 8.7 Defueled Joint Information Center Organization Emergency Plan Revision PENDING Page 69 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 thc Control Room and provides t*,hniGal support as n*e*,ssa.';

4Q3. Appropriate plant staff are directed to assume various emergency functions;

&.4. Control Room personnel notify the New Hampshire, Massachusetts and Vermont State Police. The State Police notify the appropriate state authorities;

65. The NRC is notified; 7-.6. Other support is requested as necessary; 8J7. The Emergency Call-in Method is implemented as shown in the notification plan (Figure 9.1);

-98. Additional personnel report to the plant as requested by the SM; 41-0.9.__ The Shift Manager directs the activities of emergency response personnel until overall responsibility is assumed by the Emergency Director; 1-.10. If necessary, appropriate emergency medical, fire department, or law enforcement agencies are notified and requested to respond; 4-2L.11. The TSC may be activated at the discretion of the Emergency Plant Manager; Emergency Plan Revision 54PENDING Page 82 of 125 Entergy Vermont Yankee

.12.The public information representative is notified and handles public information associated with the event; and 14.13. 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 Facility/Recovery Center, and the Joint Information Center are activated by personnel as shown in Table 9.1;

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

4. The 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 -54PENDING Page 83 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. Emergency 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 54PENDING Page 85 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 coIod; 3-2. The fission product release has been controlled;

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

&.3. An adequate heat transfer path to an ultimate heat sink has been established;

6. Reactor coolant system pressure isun;der control; and/or 7L.4. 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; ahd

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

Emergency Plan Revision 54PENDING Page 86 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 T9G MainaWe Maintenance Coordinator (Electrical/MechanicaVl&C)

Radiological Coordinator ReaetG~E)F=

Engineering Coordinator (Project, System, Design)

Operations Coordinator Engineering Support Group Operations Support Center Not activated OSC Manager Radiation Protection Staff Chemistry Staff Sparc Liccnscd Operators Spare Auxiluafy-AO s/CROs/NCOsOpefateos Control Instrument Specialists Plant Mechanics Emergency Plan Revision 6*4PENDING I Page 87 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 E=Q=Mai~iage I Administration and Logistics Coordinator Radiological Assessment Coordinator Personnel & Eguipmcnt Monitor

• Site/Offsite Monitoring Teams I Public lnformation Liaisoan Joint Information Center Not Activated Company Spokesperson VY Public Information Staff Nulea-r Public Information epsentatives Joi~nt InforM.;tion rThntpr tf

• Deployed from OSC and report to Radiological Assessment Coordinator Emergency Plan Revision 54-PENDING I Page 88 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 c'ntainmcnt condition. 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 i-eaetEr-accident exists involving actual or- p,'jete-d 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 FDNHHS 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 54PENDING Page 92 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 -hmistry 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 -54PENDING Page 93 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 PubliG-Information-Liaison-Technical Advisor 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 54PENDING Page 104 of 125 Entergy Vermont Yankee

BVY 14-018 Docket 50-271 Attachment 4 Vermont Yankee Nuclear Power Station Analysis of Proposed Post-Shutdown On-Shift Staffing (63 Pages)

VY ANALYSIS OF PROPOSED POST-SHUTDOWN ON-SHIFT STAFFING VERMONT YANKEE NUCLEAR POWER STATION ANALYSIS OF PROPOSED POST-SHUTDOWN ON-SHIFT STAFFING March 10, 2014 Prepared by:

Date Peer Review by*k_ A Date V// Date Approved by:

t(t Page 1 vy VY Page 1

VY ANALYSIS OF PROPOSED POST-SHUTDOWN ON-SHIFT STAFFING TABLE OF CONTENTS I. INT R O DUC T IO N.................................................................................................................................. 4 I1. A NA LY S IS S UMMA R Y ....................................................................................................................... 4 A. Emergency Plan Minimum Staffing ................................................................................. 5 B. Other Commitments to Shift Staffing .............................................................................. 6 C. Staffing Exceptions and Time Motion Studies (TMS) ................................................... 7 D. Emergency Plan Tasks Not Analyzed ........................................................................... 9 Ill. A NA LY S IS P R O C E S S ........................................................................................................................ 9 IV. ACCIDENT SCENARIOS ............................................................................................................ 10 A. Accident S election ............................................................................................................ 10 B. Accident Scenarios included in the Analysis ............................................................... 10 C. Accident Scenarios not included in the Analysis ......................... 11 V. GENERAL ASSUMPTIONS AND LIMITATIONS .................................................................... 12 A. Notes and Assumptions applicable to all accidents in VY Staffing Analysis: ...... 12 B. NEI 10-05 Rev 0 Assumptions ...................................................................................... 13 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS ........................................................... 15 VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS ................................................................ 16 A. Accident Analysis #1 - Design Basis Threat ................................................................ 16 B. Accident Analysis #2 - Fuel Handling Accident ........................................................... 22 C. Accident Analysis #3 - Aircraft Potential Threat ........................................................ 28 D. Accident Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP C o o lin g .................................................................................................................................... 34 E. Accident Analysis #5 -General Emergency with Radioactive Release and PAR ....... 40 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ....... 46 A. Analysis #1 - Design Basis Threat .............................................................................. 46 B. Analysis #2 - Fuel Handling Accident ......................................................................... 49 C. Analysis #3 - Aircraft Potential Threat .............................................................................. 53 D. Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling. 56 E. Analysis #5 - General Emergency with Radioactive Release and PAR ................. 59 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ...................... 63 VY Page 2

A. Overlap Requiring Com pensatory Measures ............................................................. 63 X. REFERENC ES ................................................................................................................................... 63 XI. STAFFING ANALYIS TEAM ....................................................................................................... 63 Page 3 vy VY Page 3

1. INTRODUCTION On September 23, 2013, Entergy Nuclear Operations, Inc. (ENO) informed the Nuclear Regulatory Commission that the Vermont Yankee Nuclear Power Station (VY) will permanently cease operations in the fourth quarter of 2014. Once fuel has been permanently removed from the reactor vessel, ENO will submit a written certification to the NRC, in accordance with 10 CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9). Upon docketing of these certifications, the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). In the permanently defueled condition, the Updated Final Safety Analysis Report (UFSAR) credible accidents (postulated accidents) are reduced via the 50.59 process. In order to address the transition from an operating facility to a permanently defueled facility, changes are required to preserve the effectiveness of the Emergency Plan to properly reflect the conditions of the facility.

This report details the preliminary analysis of the proposed post-shutdown on-shift staffing for VY incorporating anticipated changes to address post-shutdown and defueled conditions. Specifically, it reassigns some on-shift tasks to align with proposed changes to on-shift staffing and the resulting changes to VY Emergency Plan Implementing Procedures. This analysis will be updated and formal Time Motion Studies (TMS) will be conducted, as necessary, following development and validation of procedures that address VYs permanently shutdown and defueled conditions.

This analysis evaluates the ability of the proposed post-shutdown minimum on-shift staff to implement all emergency tasks, evaluated in accordance with NEI 10-05, Rev. 0, Assessment of On-shift Emergency Response OrganizationStaffing and Capabilities,as applicable to the permanently shutdown and defueled conditions.

This analysis satisfies the requirements of 10 CFR Part 50, Appendix E Section IV.A.9, which states that nuclear power licensees shall perform "a detailedanalysis demonstrating that on-shift personnel assignedemergency plan implementation functions are not assignedresponsibilitiesthat would prevent the timely performance of their assigned functions as specified in the emergency plan." To support reduced staffing following permanent cessation of operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents that will be applicable in the permanently defueledcondition and assumed corresponding changes to procedures. This analysis examined the capability of the proposed post-shutdown minimum staff to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planningfor Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the Emergency Plan (E-Plan).

II. ANALYSIS

SUMMARY

This analysis determined that a proposed post-shutdown on-shift staff of seven (7) is able to cope with the spectrum of analyzed events, as described in Section IV of this report, until augmenting ERO staff arrives. As VY Page 4

noted in the table below, VY may qualify Radiation Protection (RP) Technicians for Fire Brigade duties at some point in the future. If this occurs, the Fire Brigade qualified on-shift RP Technician may be called upon to act in that role, as necessary. This contingency was evaluated as part of this analysis and there are no conflicting responsibilities in the events analyzed if the RP Technician is called upon to perform as a Fire Brigade member.

During those instances when the RP Technician could be designated as a Fire Brigade member, the minimum on-shift staff of seven (7), reflected in the following table, is able to cope with the analyzed events. When the RP Technician is not designated as a member of the Fire Brigade, the on-shift staffing will consist of eight (8) personnel. The on-shift staff consists of individuals necessary to support each of the following emergency plan functional areas or tasks:

" Emergency Direction and Control

• Plant Operations and SFP Cooling

• Fire Fighting (Fire Brigade)

• Accident/Dose Assessment

" Radiation Protection

• Notification/Communication

• Access Control and Accountability NEI 10-05 states it is acceptable for certain functions to be assigned to personnel already assigned other functions/tasks. These include Repair and Corrective Action, Rescue Operations and First Aid.

A. Emergency Plan Minimum Staffing Per 10 CFR 50.54(q)(1)(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of Appendix E and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

The following table indicates the result of the NEI 10-05 staffing analysis of proposed post-shutdown on-shift personnel to perform the required emergency planning function and proposed post-shutdown minimum number for each on-shift position. These positions are the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel.

This analysis will be updated and formal TMSs will be conducted, as necessary, following development and validation of procedures that address VYs permanently shutdown and defueled conditions to verify the proposed post-shutdown on-shift staffing is appropriate.

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gBasis On-Shift Staffing Position Licensing t E-Plan Functional Area Analysis Requirement Results Shift Manager (SM) E-Plan Table 8.4 Emergency Direction and Control Control Room Supervisor Accident / Dose Assessment2 (CRS)/Certified Fuel Handler E-Plan Table 8.4 Notifications/Communications1 (CFH)I Notfctios/o___uncation Auxiliary Operator (AO #1)/Control Room Operator (CRO)/Non- E-Plan Table 8.4 FB 1 Certified Operator (NCO#1)'

Auxiliary Operator (AO #2)/Control Room Operator (CRO)/Non- E-Plan Table 8.4 FB 1 Certified Operator (NCO#2) 1 Auxiliary Operator (AO #3)/Control FB Room Operator (CRO)/Non- E-Plan Table 8.4 1 Certified Operator (NCO#3) 1 Fire Brigade #1 (FB #1) E-Plan Table 8.4 FB 3 Fire Brigade #2 (FB #2) E-Plan Table 8.4 FB 3 Radiation Protection (RP) E-Plan Table 8.4 Radiation Protection 4 Technician Security Contingency Access Control and Per Security Security Plan/E-Plan Table 8.4 Accountability Contingency Plan TOTAL 75 1 Titles are dependent upon NRC approval of proposed changes to Technical Specifications. CFHs will supervise fuel handling operations in the permanently defueled condition. The CRS and SM will be qualified as CFHs. However, the SM requires additional qualification beyond the CFH training. Therefore, any reference to the CFH position throughout this document is considered to be equivalent to the CRS position. Non-Certified Operators (NCO) will perform duties typically associated with those performed by Auxiliary Operators (AO) and Control Room Operators (CRO), such as manipulation and monitoring of plant equipment.

2CRS is assigned Accident/Dose Assessment responsibilities in the Fuel Handling Accident analyses (Analyses #2 and #5). There are no Accident/Dose Assessment tasks identified as being required during the remaining analyses.

3 Fire Brigade #1 and #2- May be provided by shift personnel assigned other functions. These positions do not have any actions or tasks that would conflict with Fire Brigade responsibilities in the events analyzed. The on-shift member is available to support the Shift Manager, where qualified, in non-fire events.

4 RP Technician may be Fire Brigade qualified at some point in the future and may be called upon to act in that role, if necessary. There are no conflicting responsibilities in the events analyzed.

5 During those instances when the RP Technician is designated as a Fire Brigade member, the minimum on-shift staff of seven (7) is able to cope with the analyzed events. When the RP Technician is not designated as a member of the Fire Brigade, the on-shift staffing will consist of eight (8) personnel.

B. Other Commitments to Shift Staffing None VY Page 6

C. Staffing Exceptions and Time Motion Studies (TMS)

1. No chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. Because the Chemistry Technician was not identified as having any specific Chemistry/Radio-Chemistry related emergency tasks during the scenarios evaluated for this analysis, the Chemistry Technician position is not included in the proposed post-shutdown on-shift staffing complement.

2. Because VY will no longer be authorized to operate the reactor or place fuel into the reactor vessel, the STA position is not included in the proposed post-shutdown on-shift staffing complement.

3. Because of the reduced actions necessary to mitigate an emergency in the permanently defueled condition and the minimal actions of the Control Room positions in a permanently defueled condition, no Control Room Operator job tasks were noted as being required for any of the analyzed events. Because the Control Room Operators were not identified as having any specific emergency tasks during the scenarios evaluated for this analysis, the Control Room Operator position is not included in the proposed post-shutdown on-shift staffing complement.

4. The Shift Manager is assigned the responsibility to make some site specific event notifications such as to the Duty Plant Manager, Operations Manager, and Resident Inspector. These notifications by phone are considered communications that are approximately one minute in length and are deemed acceptable in accordance with NEI 10-05 Section 3.2.2 (6)(a)(14) due to the short duration of the notifications. Additionally, these notifications are collectively evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills and are not deemed as impacting the Shift Managers ability to maintain oversight of the event or perform other required emergency plan tasks. In accordance with the guidance of NEI 10-05, Line 14 of NEI Table 5 contained in Section VII of this report does not reflect the performance of these short duration notifications. No further analysis or TMS is required.

5. Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the capability of the CRS to perform the Notification/Communication responsibilities assigned in each analysis. The VY process for completing state and local emergency notification forms and performing the off-site notifications is automated and requires minimal manual actions. TMSs were conducted and demonstrated that these tasks could be performed by the on-shift CRS without impacting the ability of the CRS to remain in role providing support and oversight during the emergency. The TMSs demonstrated the Notification/Communication responsibilities could be performed individually or in series without impacting the CRS function. The results are documented in Section VIII of this analysis.

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6. Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the capability of the CRS to perform the Dose Assessment responsibilities assigned in Analyses #2 and #5. VY 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. A TMS was conducted and demonstrated that these tasks could be performed by the on-shift CRS without impacting the ability of the CRS to remain in role providing support and oversight during the emergency. The TMSs demonstrated this task could be performed individually or in series with off-site notifications without impacting the CRS function. The results are documented in Section VIII of this analysis.

7. Station staff are required to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(hh) and Reg, Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The analysis of this event identified there are sufficient personnel on-shift to perform this task during the event. No further analysis or TMS is required.

8. A TMS was conducted during development of the Vermont Yankee On-Shift Staffing Analysis Report, dated December 19, 2012 to determine if the Shift Manager could perform the task of notifying the ERO of the emergency while continuing to maintain emergency direction and control.

The TMS demonstrated the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO using Everbridge. This evaluation may be used to allow the Shift Manager to perform this task if desired. No further analysis or TMS is required.

9. The VY Emergency Response Data System (ERDS) link to the NRC will not be operational in a permanently shut down and defueled condition. The task of ERDS activation is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

10. NRC event notifications required due to the declaration of an Emergency Classification in accordance with 10 CFR 50.72 is made in accordance with EPOP-CR-3540.. A written event notification form is generated by on-shift staff for this notification.

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D. Emergency Plan Tasks Not Analyzed

1. Repair and Corrective Action - Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by shift personnel assigned other functions. Repair and corrective action is defined as:

An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g.,

open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete.

In accordance with NEI 10-05 section 2.5, the analysis included a review of repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

• Unplanned/unexpected actions that address equipment failures. These actions are contingent in nature and cannot be specified in advance.

• Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

At VY, AO/CRO/NCOs are trained to perform the actions associated with this functional area.

Actions (e.g., reset breakers, valve manipulation) directed by the Control Room Supervisor/Certified Fuel Handler (CFH) to mitigate the event per procedures were performed by the AO/CRO/NCOs in this analysis. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed.

2. Rescue Operations and First Aid: In accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response although neither task was required during the evaluated scenarios. Per the guidance of NUREG-0654, Table B-i, rescue operations and first aid may be performed by shift personnel assigned other functions. The station fire brigade staff is trained in first aid and rescue operations and is available to perform these tasks if required. First aid and rescue operations are acceptable collateral duties per the guidance of NEI 10-05.

Ill. ANALYSIS PROCESS The Vermont Yankee On-Shift Staffing Analysis Report, Rev. 0, dated December 19, 2012, was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Licensing, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments.

Additionally, members of the Security staff provided input to the analysis. Revision 1 of this report (December 19, 2013) was developed based on input, reviews and concurrence from station personnel from the same departments as those participating in the original analysis.

VY Page 9

The current analysis was developed by reviewing each scenario from Revision 1 to determine its applicability in a permanent shutdown and defueled condition and what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel, ensuring that no actions were assigned to staff members that conflicted with either their proposed emergency plan role or operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, an evaluation of the timing of the tasks was conducted to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Section VII, APPENDIX B - ON-SHIFT STAFFING ANALYSIS. Note that NSIR DPR-ISG-01 states that only Design Basis Accidents (DBA) "which would result in an emergency declaration" should be evaluated in the staffing assessment. In a permanently shutdown and defueled condition UFSAR Chapter 14 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition. These DBAs include the control rod drop accident, loss of coolant accident, main steam line break.

IV. ACCIDENT SCENARIOS A. Accident Selection

1. The OSA scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01, based on the applicability in a permanent shutdown and defueled condition. The evaluation considered the station DBAs described in the UFSAR along with additional scenarios specified by the guidance documents. The following scenarios were considered for inclusion in this analysis:

• Design Basis Threat (DBT) ground assault as described in NEI 10-05

• DBA Fuel Handling Accident (FHA).

• Aircraft Potential Threat as described in 10 CFR 50.54(hh).

0 Fire requiring evacuation of the Control Room, (Appendix R Fire) as described in NEI 10-05

• General Emergency with radioactive release and Protective Action Recommendation (PAR) as described in NEI 10 assumed for analysis purposes.

• Station Blackout (SBO) as described in NEI 10-05.

B. Accident Scenarios included in the Analysis

1. Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

VY Page 10

2. Fuel Handling Accident (FHA)

The postulated design basis accident that will remain applicable to VY in its permanently shutdown and defueled condition is the FHA in the reactor building where the SFP is located. A revised FHA analysis has been developed to address the permanently defueled condition to determine the dose to operators in the Control Room and the public at the Exclusion Area Boundary (EAB or Site Boundary) and Low Population Zone. This accident analysis assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

3. Aircraft Potential Threat (50.54(hh))

• Notification is received from the NRC that a potential aircraft threat exists (>5 minutes,

<30 minutes).

4. Fire requiring evacuation of the Control Room and control of service water pumps from a remote location

• A fire occurs requiring the evacuation of the Control Room and procedures implemented to control service water pumps from a remote location.

5. General Emergency (GE) with radioactive release and PAR (assumed for analysis purposes)

• This event is based on the same initial conditions as the FHA, but assumes a dose that exceeds the Environmental Protection Agency's (EPA) Protective Action Guides (PAGs) beyond the site boundary, and thus necessitates promulgation of a PAR.

C. Accident Scenarios not included in the Analysis

1. Station Blackout ISG-01 provides guidance associated with the staffing analysis for a Station Blackout (SBO). ISG-01 states, in part:

Station blackouts are beyond the plant's design basis and may not need to be addressedin the staffing analysis. The blackout coping analyses performed by licensees pursuantto 10 CFR 50.63 establish blackout coping times that exceed the required on-shift staff augmentation time.

Also, since the control room fire scenarioleading to evacuation and remote shutdown may adequately address the considerationsinvolved with an Appendix R "safeshutdown" fire, licensees may not need to consider this scenario in the staffing analysis.

10 CFR 50.63(a)(1) states, in part:

Each light-water-coolednuclearpower plant licensed to operate under this part,each light-water-cooled nuclearpower plant licensed under subpart C of 10 CFR part 52 after the Commission makes the finding under § 52.103(g) of this chapter,and each design for a light-water-cooled nuclearpower plant approved under a standarddesign approval,standarddesign certification, VY Page 11

and manufacturinglicense underpart 52 of this chapter must be able to withstand for a specified duration and recover from a station blackout as defined in § 50.2.

Once VY submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii),

per 10 CFR 50.82(a)(2) the Part 50 license will no longer authorize operation of the reactor or emplacement of fuel in the reactor vessel. VY will no longer be a nuclear power plant licensed to operate under 10 CFR Part 50 and 10 CFR 50.63 will no longer be applicable. The SBO scenario is no longer considered an appropriate gauge by which to measure whether an event presents on-shift staff with responsibilities that would prevent the timely performance of assigned functions in the E-Plan. Therefore, this scenario is not considered in this analysis.

2. Appendix R Fire That Results in a Reactor Trip 10 CFR 50 Appendix R is applicable to licensed nuclear power generating stations. Once the certifications required by 10 CFR 50.82(a)(1) are docketed, VY will no longer be licensed to generate nuclear power. The Appendix R fire scenario is no longer considered an appropriate gauge by which to measure whether an event presents on-shift staff with responsibilities that would prevent the timely performance of assigned functions in the E-Plan. Therefore, this scenario is not considered in this analysis.

V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions applicable to all accidents in VY Staffing Analysis:

1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Operations procedures for Off-Normal and Emergency conditions, and Emergency Plan procedures and checklists. Any additional tasks directed by the Technical Support Center (TSC),

Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.

2. VY has 30 and 60 minute emergency responders when augmented while the ERO is offsite. This analysis was conducted assuming a 90 minute response of the augmented ERO to allow the use of this analysis for a possible future extension in ERO augmentation times. There were no specific emergency response tasks assigned to the augmented ERO prior to the 90 minute response.

3. There are no time critical RP or Chemistry tasks and task performance is directed and prioritized by the Shift Manager. The time RP is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration. Because the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.

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B. NEI 10-05 Rev 0 Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. As noted above, this analysis assumed a 90 minute augmentation time although the times noted in the Table 1 accident analysis tables reflects the E-plan required staffing times of 30 or 60 minutes.

2. On-shift personnel complement was based on the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel.

3, Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.

4. Each analyzed event occurred during off-normal work hours where the ERO was offsite and all required minimum on-shift positions were filled.

5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

6, On-shift staff had necessary Radiation Worker qualification to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of an RP technician.

7, Personnel assigned plant operations met the requirements and guidance (analyzed through other programs such as operator training) and were not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

8. In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain SFP cooling was done by a member of the on-shift staff as defined in the unit's Tech Specs.

9, Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

10. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.

11. Communications, briefings, and peer checks are acceptable collateral duties.

12. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIR/DPR-ISG-01]

13. The Staffing Analysis specified the resources available to perform "Repair and Corrective Actions" and "Rescue Operations and First Aid" but these may be assigned as collateral duty to a designated on-shift responder.

14. For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71 (b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.

VY Page 13

15. DBA (postulated accident, Condition IV event, or limiting fault) is considered as "Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel."

16. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to interrupt SFP cooling or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.

17. The Staffing Analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the UFSAR.

18. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began 15-minutes after the initiating event.

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VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS Event Event SummaryReference Analysis Description of Plant Modele n Event ECLmAnalysis SDocument(s) Required?

1 DBT Land and/or Permanently NEI 10-05 Site Area Yes waterborne Defueled Emergency HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

2 DBA Fuel Handling Permanently UFSAR Chapter 14 Alert Yes Accident Defueled (as revised to address permanently defueled conditions) 3 Assumed Aircraft Potential Permanently 10CFR50.54hh(1) Alert Yes for Threat Defueled Analysis RG 1.214 Purpose 4 Assumed Control Room Permanently 10 CFR Part 50.48 Alert Yes for Evacuation and Defueled Analysis transfer control to Purpose remote location (fire in main control room) 5 Assumed General Permanently ISG IV.C General Yes for Emergency with Defueled Emergency Analysis radiological release Purpose and PAR 6 Assumed Station Blackout Permanently 10CFR50.63 Site Area Noz for Defueled Emergency Analysis*

Purpose 7 Assumed Appendix R Fire Permanently ISG IV.C Alert Nou for Defueled Analysis Purpose Once VY submits the certification of permanent removal of fuel inaccordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement of fuel inthe reactor vessel. VY will no longer be a nuclear power plant licensed to operate under Part 50.

2Once VY submits the certification of permanent removal of fuel inaccordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement of fuel inthe reactor vessel and 10 CFR 50.63 will no longer be applicable.

3 Upon Termination of License as prescribed under 10 CFR 50.82 VY's Fire Protection program will fall under 10 CFR 50.48 (f)which requires the maintenance of a fire protection program to address the potential for fires that could result inthe release or spread of radioactive materials..

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VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS A. Accident Analysis #1 - Design Basis Threat

1. Accident Summary Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

2. Accident Specific Assumptions Made

• The VY DBT for this analysis assumes a land based threat.

• This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

• Assume Spent Fuel Pool Temperature of 1250 F.

• Security notifies the Shift Manager of condition of hostile action occurring within the protected area (Security code RED)

• Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.

• Assume all systems function and the spent fuel remains covered. No fuel damage and no release.

3. Procedures for Accident Response

• OPOP-SECU-3132, Operations Response to Security Events

• EPOP-CR-3540, Control Room Actions During an Emergency

• OP3547, Security Actions During an Emergency Page 16 vy VY Page 16

4. Tables

. VY= TABLE1 - ON-SHIFT POSITIONS:

A.;

nalysis 1 DBT Security Threat LieAugm1fentation Role In snehlft Position E -Plan Reference ElapsTime (W____.__ Table Unanalyzed TMS

)*.

Ela__imn______ Line, .. TasKk? ReqUired?

T2/L1

• T5/L1 Yes' 1 SM Emergency Plan 60 T5/L3 No Table 8.4 T5/L5 T5/L6_

T2/L2 T5/L7*

2 CRS Emergency Plan N/A T5/ L8 No Yes2 Table 8.4 T5/L9 T5/L10 T5/113 3 AO/CRO/NCO Emergency Plan N/A N/A No No

1. 1 Table 8.4 N/A N/A NoNo 4 AO/CRO/NCO #2 Emergency Plan N/A N/A No No

1. able 8.4 5 AO/CRO/NCO 5 __AO/CRO/NCO_ #3/ Emergency

1. 3Table Plan N/A N/A No No 8.4 6 FB #1 Emergency Plan N/A N/A No No Table 8.4 7 FB #2 Emergency Plan N/A N/A No No Fable 8.4 8 RP Emergency Plan 30 N/A No No 8able 8.4 Security Security Contingency Plan / N/A T5/L15 No No Emergency Plan F'able 8.4 1

.." -,pL. =

Guiaance provideu in I able I. IO rNa- i u-uo indicates me need to pernorm a I MI to verity me results OT ntis analysis. i ne Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the December 2012 OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO using Everbridge. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.A

• Expected duration of less than 1 minute. Therefore, Task not included in the TMS included in Section VIII.A.

Page 17 vy VY Page 17

VT TABLE 2 - PLANT OPERATIONS...

One Unit - One Control Room:

ANALYSIS# 1 DBT Security Threat .

Minimum:Operations Crew Necessary to. Implement AOPs. and EOPs if.Applicable:

Line.* Generic.Title/Role . On-ShiftfPo6sition Task Analysis

____ ___ ____ __ ___ ____ ___ ___Controlling Method 1 Shift Manager SM Licensed Operator Training Program 2 Unit Supervisor CRS Licensed Operator Training I I_ Program Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs if Applicable Line . Generic Title/Role On-Shift Position ...... Ts hAnalysis

___________...___.: ____ Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Page 18 vy VY Page 18

Fire Brigade

• ~VY TABLE 3- FIREFIGHTING

• ... . ANALYSIS,#.1 DBT Security Threat Line by .PerformedTask Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

Page 19 vy VY Page 19

VY TABLE 4 - RADIATION PROTECTION AND C;HEMISTRY Analysis # 1 DBT Secur ity Threat.

L Position Performing Performance Time Period After Emergency Declaration (minutes)

I Function. / Task

.55-15 0N 5 10-,15 25- 30-3O356, 40: 45 55 65Z 70 80- 85-_

.....  : , 1 .20 2,5 30 3.5 40

.1.E5 45 50 55 60, 65 ý70 75 80 85 90; 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 ob Coverage: N/A 5 ffsite Rad ssessment: N/A 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A No chemistry or RP job function tasks for the conditions described in the DBT assumptions. RP takes cover as directed.

Page 20 vy VY Page 20

VY.TABLE 5--E5UEMERGENCY PLAN IMPLEMENTATION

."An.a.lys... .... # DBT Security Threat In Function Task On-Shift Task Analysis Controlling Method Position -

Declare the emergency classification level Shift Emergency Planning Training 1 (ECL) Manager Program / EP Drills 2 ,pprove Offsite Protective Action N/A N/A Recommendations 3 Approve content of State/local notifications Shift Emergency Planning Training Manager Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Shift Licensed Operator Training Program /

oassemble, evacuate, etc.) Manager Emergency Planning Training I Program 6 ERO notification Shift Emergency Planning Training Manager Program 7 Abbreviated NRC notification for DBT event CRS Licensed Operator Training Program Emergency Planning Training Complete State/local notification form CRS Program 9 Perform State/local notifications CRS Emergency Planning Training I_ Program iform CRS Emergency Planning Training 10 Complete NRC event notification Program 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications CRS Licensed Operator Training Program 14 Perform other (e.g., Duty site-specific Plant Manager, event INPO, notifications ANI, etc.) N/A N/A N/A N/A 15 Personnel Accountability Security Security Training Program / EP Drills Page 21 vy VY Page 21

B. Accident Analysis #2 - Fuel Handling Accident

1. Accident Summary

• The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

2. Accident Specific Assumptions Made

• This analysis assumes an ALERT declaration based on area radiation monitors reaching levels to prompt an emergency declaration.

• Additional station personnel, including Operations and Health Physics Technicians, would be on-site during fuel assembly movement. Additional station personnel were not required, however, to support initial response actions.

3. Procedures for Accident Response

• OP 1101, Management of Refueling Activities and Fuel Assembly Movement

• OP 1100, Refuel Platform Operation Page 22 vy VY Page 22

4. Tables VY TABLE 1- ON-SHIFT POSITIONS..

Analysis #2- Fuel Handling Accident .

Augmentation Role In Table K Line On-shift Position" E-Ptan Reference Elapsed.Time . Line . Unanal.zed TMS ...

1. _______ __________ (m) Task? Required?

T2/L1 SM Emergency Plan T5/L1 1

Table 8.4 60 T5/L53 No Yes T5/L5 T2/L2 T5/L8 2 CRS Emergency Table 8.4 Plan N/A T5/L9 T5/L10 No Yes 2 T5/L1 2 T5/L13 3 AO/CRO/NCO #1 Emergency Plan N/A N/A No No Table 8.4 4 AO/CRO/NCO #2 Emergency Plan N/A N/A No No Table 8.4 5 AO/CRO/NCO #3 Emergency Plan N/A N/A No No Table 8.4 6 FB #1 Emergency Plan N/A N/A No No Table 8.4 7 FB #2 Emergency Plan N/A N/A No No Table 8.4 8 RP Emergency Plan 30 T4/L2 No No Table 8.4 Security Contingency 9 Security Plan / Emergency N/A T5/L15 No No I_____ Plan Table 8.4 [___

Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the results of this analysis. The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the December 2012 OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO using Everbridge. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.B Page 23 vy VY Page 23

VYTABLE 2 - PLANT. OPERATIONS&*<:.....

,,.One Unit -one Control Room ANALYSIS4#2. Fuel Handling Accident Minimum Operations Grew Necessary to Implement AOPs and EOPs ifApplicable iLine # Generic Title/Role On-Shift Position ?  : TaskAnalysis:

______________________________ ___________________ ControllIng Method%

1 Shift Manager SM Licensed Operator Training Program 2 Unit Supervisor CRS Licensed Operator, I I Training Program Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs ifApplicable Line. .. Generic Title/Role On-Shift Position Task Analysis":

____ ___Controlling Method1 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Page 24 VY vy Page 24

Fire Brigade VY TABLE 3 - FIREFIGHTING .

ANALYSIS # 2 - Fuel Handling Accident Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

Page 25 vy VY Page 25

VY TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #2- Fuel Handlina Accident I. Position Performing PerformanceTimePeriod 'AfterEmergency Deciaration -(minutes)*

I Function /Task N ::,*:  :,*: .. 05- 10- 15 .. 20 30- 35: 40 '50 55- 60 .65-70-. 75 85 N  ::15 201::2530 35: 5:50 5560 657075 8 85, '90.,

1 In-Plant Survey: N/A 2 n-site Survey: RP X X X X XX x x x x 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment:

(Included in Table 5 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A I ne time to commence anr complete the iaSK Is estimaied.

vy Page 2 VY Page 26

VY TAL -EMERGENCY PLAN IMPLEMENTATION.

Analysis E #2- Fuel N Handling"Accident:.

LM A . B ..

____:_...V .

,Line. Function ITask On-Shift. Position Task Analysis-Controlling

1. _ _ _ _ _ _ _ _ _ _ _Method :__

Declare the emergency classification level Emergency Planning 1 (ECL) Shift Manager Training Program / EP

( Drills N/A N/A 2 Approve Offsite Protective Action Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 to assemble, evacuate, etc.) Shift Manager Program / Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form CRS Emergency Planning Training Program 9 Perform State/localI notifications CRS Emergency Planning Training Program 10 Complete NRC event notification form CRS Emergency Planning Training Program 11 Activate ERDS N/A N/A 12 Offsite radiological assessment CRS Emergency Planning I Training Program Licensed Operator Training 13 notifications Perform NRC IProgram CRS PrOgram 14 Perform other site-specific event notifications N/A N/A

_(e.g., Duty Plant Manager, INPO, ANI, etc.) I I 15 Personnel Accountability Security Officer Security Training Program Page 27 vy VY Page 27

C. Accident Analysis #3 - Aircraft Potential Threat

1. Accident Summary

• The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214.

• The analysis does not include a scenario or response actions taken during or after a crash.

2. Accident Specific Assumptions Made

• The Shift Manager receives the call from the NRC of potential aircraft threat.

• All non-security on-shift personnel are inside the protected area fence at their normal workstation.

3. Procedures for Accident Response

• ON3177, Operations Response to an Aircraft Threat

• EPOP-CR-3540, Control Room Actions During an Emergency Page 28 vy VY Page 28

4. Tables S..... VY TABLE 1 - ON-SHIFT POSITIONS

_An....Analysis #3 - AircraftfPotential Threat Linen i P o -n Augmentation, Role in Table iUnanalyzed . . TMS.

Reference n ;mf Posminon Elapsed Time. # /Lin e ..* Task? Required?

T2/L1 T5/L1 Yes' 1

SM Emergency Plan 60 T5/L3 No Table 8.4 T5/L5 T5/L6 T2/L2 2 CRS Emergency Plan N/A T5/L9 No Yes2 Table 8.4 T5/L13 3 AO/CRO/NCO #1 Emergency Plan N/A T3/L1 No No Table 8.4 4 A # Emergency Plan N/A T3/L2 No No

____/_R__/N 2Table

__O 8.4 5 AO/CRO/NCO #3 Emergency Plan N/A T3/L3 No No Table 8.4 6 FB #1 Emergency Plan N/A T3/L4 No No Table 8.4 7 FB #2 Fable Emergency Plan 8.4 N/A T3/L5 No No 8 RP Emergency Plan 30 N/A No No 8"able 8.4 Security 9 Security Contingency Plan N/A T515 No No 9 Emergency Plan

[Table 8.4 1 1 Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the results of this analysis. The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the December 2012 OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO using Everbridge. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.C.

Page 29 vy VY Page 29

VY TABLE 2- PLANT OPERATIONS & SAFE SHUTDOWN..

• One Unit-OneControl Roomr,.

Analysis #3 -Aircraft Potential Threat ,

Minimum Operations Crew Necessary to Implement AOPs and EOPs if ApplicableK...... ....

Line,# Genieric Title/Role On-Shift Position' *Task Analysis

"_.,___*____*_"_~_"_~_""_~__~._*C'_'_

___  ; Controlling Method SM Licensed Operator 1 Shift Manager Training Program Unit Supervisor CRS Licensed Operator 2

IT I _raining Program Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs if Applicable

..,Line # GenericTieIRole On-Shift Position TaskAnalysis Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 l&C Technician N/A N/A 6 ther N/A N/A 7 ther N/A N/A Page 30 vy VY Page 30

Fire Brigade VY. TABLE. 3 - FIREFIGHTING.

Ana in.ysi#3 -Aircraft PotentialaIThreat.

Line Performed by ' Task Analysis Controlling Method 1 AO/CRO/NCO #1 Fire Protection Program 2 AO/CRO/NCO #2 Fire Protection Program 3 AO/CRO/NCO #3 Fire Protection Program 4 FB#1 Fire Protection Program 5 FB#2 Fire Protection Program This accident does not include the need for firefighting, first aid or search & rescue. The Fire Brigade relocates outside the PA and stands by in the Plant Support Building.

Page 31 vy VY Page 31

VTY TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 6 Aircraft Threat VY7TABLE 4- RADIATION.PROTECTION AND CHEMISTRY L Position:Perform ing!:

____________Anailysils

.. :. . #3

... - Aircraft:* Potential

• . Thre~at. ... . . .

Posiction Performing .Performance Time .Period After Emergency Declaration (minutes)*

I1 Function/Task

.N .:10- 15 25- 30* ;3540 45& 50 60- 65m ý70. 75-80-m85-E.____________ 0 5 15 20 25 30 35J.40 45 50 55 60 65 70"75 80' 85 90 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 [ob Coverage: N/A 5 Offsite Rad Assessment:

(Includedin Table 5

- N/A 6 Other site specific RP (describe): N/A**

7 Chemistry Function task #1 (describe) -

N/A 8 Chemistry Function task #2 (describe) -

N/A

• Times are estimated.

• • The Radiation Protection Technician has assigned no tasks in response to this event and would be available, if needed, to maintain continuous communications with the NRC during the event.

Page 32 vy VY Page 32

VY TABLE 5- EMERGENCY PLAN IMPLEMENTATION,;.

Analysis #3 - Aircraft Potential Threat..

Line - Function I Task* On-Shift Position Task Analysis Controlling

1. U ______, __________....._____ _,______, __, __ Method,.

1 Declare the emergency classification level hift Manager Emergency Planning 1 (ECL) SfagTraining Program / EP Drills Approve Offsite Protective Action N/A N/A 2

Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A 5 Notification and an direction directio to to on-shift staff (e.g., Shift Manager Licensed Operator Training Program / Emergency o assemble, evacuate, etc.) Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form N/A N/A 9 Perform State/local notifications CRS Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Licensed Operator Training Perform NRC notifications CRS Program 13 Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program Note 1: Lines 8 and 10 are not performed during an aircraft threat.

Page 33 vy VY Page 33

D. Accident Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling

1. Accident Summary This event involves a large transient fire requiring evacuation of the Control Room. The event has the potential to include shorts and/or spurious signals producing potential to lose SFP cooling capabilities.

2. Accident Specific Assumptions Made

• Assumed control room staff does not have time to perform any procedural actions other than declare the Alert and make the plant announcement before leaving the control room.

3. Procedures for Accident Response

• EPOP-CR-3540, Control Room Actions During an Emergency

• OP 3547, Security Actions During an Emergency Page 34 vy VY Page-34

4. Tables VY TABLE 1 - ON-SHIFT POSITIONS

______________*,',:*?: Analysis #4- CR Evacuation & SFP Cooiing _______.. ._

L ineE Pa , . 1 ..

.. 1 .... ..-.. %:. ý i.

n e.. . .. .... .. . ..

Lie .. Augmentation Rolein Table . Unanalyzed' TMSI ..

Pnoshift Position e-Plan Elapsed Time  :.Line # . Task? Required?

n-shift Reference (m _____ _____ _____

T2/L1 T5/L1 1SM Emergency Plan 60 T5/L3 No Yes1 Table 8.4 T5/L5 T5/L6 T2/L2 T5/L8 CRS Emergency Plan N/A T5/L9 No Yes 2 Table 8.4 T5/L10 T5/L13 3 AO/CRO/NCO #1 Emergency Plan N/A T3/L1 No No Table 8.4 4 AO/CRO/NCO #2 Emergency Plan N/A T3/L2 No No Table 8.4 5 AO/CRO/NCO #3 Emergency Plan N/A T3/L3 No No Table 8.4 6 FB #1 Emergency Plan N/A T3/L4 No No 6 __FB_#1 Table 8.4 7 FB #2 Emergency Plan N/A T3/L5 No No Table 8.4 8 RP Emergency Plan 30 N/A No No Table 8.4 ecurity Security ontingency Plan SEmergency N/A N/A No No Table 8.4 Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the results of this analysis. The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the December 2012 OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO using Everbridge. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.D.

Page 35 vy VY Page 35

'. VYTABLE 2- PLANT4OPERATIONS -

One Unit-One Control. Room Analysis #4- CR Evacuation & SFP. Cooling, Minimum Operations Crew Necessary to Implement AOPs and EOPs if Applicable Line # Generic Title/Role On-Shift Position *..Task .Analysis

_ _ _ _~__.... ...

_...... . . ________ Controlling :Melthod Shift Manager SM Licensed Operator 1 Training Program Unit Supervisor CRS Licensed Operator 2 _raining

_T Program Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs if Applicable Line # . GenericTitle/Role* On-Shift Position.:`,*. Task Analysis:

__ _.......... ". .Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 ther N/A N/A 7 ther N/A N/A Page 36 vy VY Page 36

Fire Brigade VY TABLE 3:- FIREFIGHTING.:

Analysis #4 - CR Evacuation & SFP"Cooling Line Performed by. . Task Analysis Controlling Method 1 AO/CRO/NCO #1 Fire Protection Program 2 AO/CRO/NCO #2 Fire Protection Program 3 AO/CRO/NCO #3 Fire Protection Program 4 FB#1 Fire Protection Program 5 FB#2 Fire Protection Program Page 37 vy VY Page 37

VY TABLE 4 'ýRADIATION PROTECTION.AND.CHEMISTRY........

__________.... AnalysiS #4--CR Evacuation&SFP CoolinP L.Position Performing SFunctionTask ,Performance _ _ _ _ _ _ _ __.

Time Period After Emergency Declaration (minutes)* ..

E: A-0ý1520'. 25 30.* 3540 45 50 55 -1 60 65 70 75 80 85 . 90-1 In-Plant Survey: N/A 2 rn-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment:

(lncluded in Table 5 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe) -

N/A 8 Chemistry Function task #2 (describe) -

N/A No specific time critical tasks were identified for RP or Chemistry for this event.

Page 38 vy VY Page 38

Y.....YY TABLE 5.-ý EMERGENCY PLAN IMPLEMENTATION Analvsis #4 - CR Evacuation :& SFP Coolina:::

Line. Function /Task* On-Shift Position -Task Analysis

• 1. _____________"______________ _____ __,______""___:" _ ?Controlling Method Emergency Planning 1 eclare the emergency classification level Shift Manager Training Program / EP ECL) [Drills 2 pprove Offsite Protective Action I/A N/A

[Recommendations 3 Emergency Planning 3 ,pprovecontent of State/local notifications hift Manager Erainingy Program 4 Approve extension to allowable dose 1N/A N/A Licensed Operator 5Notification and direction to on-shift staff Training Program /

(e.g., to assemble, evacuate, etc.) hift ManagerEmergency Planning Training Program nhift Manager Emergency Planning ERO notification hraining Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form CRS Emergency Planning 9rainincProglram 9 Perform State/local notifications CRS Emergency Planning Training Proglram 10 omplete NRC event notification form CRS Licensed Operator Training Program 11 ctivate ERDS N/A N/A 12 ffsite radiological assessment N/A N/A 13 Perform NRC notifications R ffLicensed Operator RSraining Program 14 Perform other site-specific event notifications N/A N/A Ke.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability N/A N/A vy Page 3 VY Page 39

E. Accident Analysis #5 -General Emergency with Radioactive Release and PAR

1. Accident Summary (Assumed for Staffing Analysis Purpose)

• The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

• A General Emergency is declared when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.

2. Accident Specific Assumptions Made

• The UFSAR does not contain detailed radiological conditions or release rates to determine an EAL classification. This analysis, therefore, assumed a General Emergency declaration based on area radiation monitors reaching levels to prompt an emergency declaration.

• Additional station personnel, including Operations and Health Physics Technicians, would be on-site during fuel assembly movement. Additional station personnel were not required, however, to support initial response actions.

3. Procedures for Accident Response

• OP 1101, Management of Refueling Activities and Fuel Assembly Movement

• OP 1100, Refuel Platform Operation

• SAPs

• EPOP-CR-3540, Control Room Actions During an Emergency

• OP3513, Evaluation of Offsite Radiological Conditions 0 OP3510, Offsite and Site Boundary Monitoring

• EPOP-PAR-351 1, Offsite Protective Action Recommendation Page 40 vY VY Page 40

4. Tables VY.ABLE .

............ N-SHIFT POSITIONS

.. __* __*_...A.. Analysis.#5E-G Ewith PAR Line Position. *Plan.....Augmentation* Role in Table Unanalyzed TMS. Required?

... On-shif:teElapsed.Time Positio".n Reference Line # > iii ii*

'*,* : *~ ) ::**!,:* # :.. Task?**::** .:i*!::**:::  :**::

T2/L1 T5/L1 T5/L2 1 SM Emergency Plan 60 T5/L3 No Yes' able 8.4 T5/L4 T5/L5 I_ _T5/L6 T2/L2 T5/L8 2 CRS Emergency Plan N/A T5/L9 No Yese Table 8.4 T5/L10 T5/L12 T5/L13 3 AO/CRO/NCO #1 Emergency Plan N/A N/A No No Table 8.4 4 AO/CRO/NCO #2 Emergency Plan N/A N/A No No Table 8.4 5 AO/CRO/NCO #3 Emergency Plan N/A N/A No No Table 8.4 6 FB #1 Emergency Table 8.4 Plan N/A N/A No No 7 FB #2 Emergency Plan N/A N/A No No Table 8.4 8 RP Emergency Plan 30 T4/L1 No No Table 8.4 T4/1N2 Security Contingency 9 Security Plan / N/A T5/L15 No No Emergency Plan Table 8.4 Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the results of this analysis. The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the December 2012 OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO using Everbridge. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.E.

Page 41 vy VY Page 41

VY TABLE 2- PLANT OPERATIONS & SAFE SHUTDOWN

...One Unit - One Control Room Analysis #5- GE with PAR .......

Minim nmOperations Crew Necessary to Implement AOPs and EOPs if Applicable Line # Generic Title/Role On-Shift Position TaskAnalysise

___ ___ ___ ___ ___ __ ____ ___ ___ ___ Controlling.Method, Shift Manager SM Licensed Operator 1 Training Program CRS Licensed Operator IT 2 IUnit Supervisor _raining Program Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs if Applicable Line # ** Generic Title/Role, On-Shift Position cTaskAnalysis

________________________ _______________Controlling Method 5 Mechanic N/A N/A 6 Electrician N/A N/A 7 I&C Technician N/A N/A 8 Other N/A N/A 9 Other N/A N/A Page 42 vy VY Page 42

Fire Brigade

< VY

.. TABLE. 3- FIREFIGHTING Analysis#5- GE with PAR:..

Line ' ::+*÷*. ~......................................

P performed bY . aSk Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

Page 43 VY vy Page 43

S..-. .. V~~YVTABLE 4. RADIATION PROTECTION AND CHEMISTRY

___________Analysis #5 "GE with1PART.

L Peformng'Performance Poitio Time Period After-Emergency, Declaration (minutes)*

,I Function/Task____

'N0 0*510w 20- 25-

.60 35!0

.50-455ý- -45,w 65- 70..75.

. 80- 85-:*

E-_______ 15. 20! 25. '30 35' 40ý 45ý1 50, 55- 60. ý,65 70 75; 80 85 90' 1 In-Plant Survey: RP x xx x xx x 2 On-site Survey: RP x x 3 Personnel Monitoring: N/A 4 rob Coverage: N/A 5 Offsite Rad Assessment: See

__Table 5 6 Other site specific PP (describe): N/A R

7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A RP will survey areas as directed by the SM. It was assumed the RIP performs in-plant surveys and onsite surveys throughout the event until relieved by the oncoming ERO. Times* indicated above are estimated. There are no time critical P tasks.

Page 44 vy VY Page 44

VY ON-SHIFT STAFFING ANALYIS REPORT Y TABLE 5. EMERGENCY PLAN IMPLEMENTATION.

V..

Analysis.#5- GE with PAR

.Line Function/Task* On-nShift Position Task Analysis*.

_________________________ ______________ ontrolling, Method Declare the emergency classification level Emergency Planning 1 DECL) Shift Manager Training Program / EP

( Drills 2,pprove Offsite Protective Action Emergency Planning 2Recommendations Training Program 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 pprove extension to allowable dose Shift Manager Emergency Planning Training Program Licensed Operator 5Notification and direction to on-shift staff Training Program /

(e.g., to assemble, evacuate, etc.) hift Manager Emergency Planning Training Program 6 -'RO notification Shift Manager Emergency Planning 6ETraining Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form CRS Emergency Planning Training Program 9 Perform State/local notifications CRS Emergency Planning I _Training Program Licensed Operator 10 Complete NRC event notification form CRS rining pror Training Program 11 Activate ERDS N/A N/A 12 ODffsite radiological assessment CRS Emergency Planning Training Program Licensed Operator 13 Perform NRC notifications CRS rining Pr Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

15 FPersonnel Accountability Security Security Training Program Page 45 vy VY Page 45

VY ON-SHIFT STAFFING ANALYIS REPORT VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A. Analysis #1 - Design Basis Threat TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #1 Design Basis Threat TASK 1: Complete the State Notification Form Using InForm JOB: Control Room Supervisor TASK 2: Transmit the State Notification Form Using InForm JOB: Control Room Supervisor TASK 3: Perform NRC Notification JOB: Control Room Supervisor TASK 4: Perform Event Mitigation JOB: Control Room Supervisor Page 46 vy VY Page 46

VY ON-SHIFT STAFFING ANALYIS REPORT PURPOSE:

Perform a Time Motion Study to evaluate whether the performance of notification actions assigned to the Control Room Supervisor is an acceptable task overlap to the Control Room Supervisor's primary emergency plan function of event mitigation.

NOTE:

The Time Motion Study should be completed in a simulator training scenario to demonstrate notification actions while the Shift Manager is demonstrating the Emergency Director function.

CONCLUSION:

The Time Motion Study demonstrated the Control Room Supervisor could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the CRS to remain in role providing support and oversight during the emergency.

LOCATION:

Simulator REQUIRED TOOLS/EQUIPMENT:

A. Attachment 9.5 of Procedure OP 3513, "Evaluation of Offsite Radiological Conditions" B. Procedure EPOP-PAR-351 1, "Off-Site Protective Action Recommendations" C. Stopwatch or watch to time actions Page 47 vy VY Page 47

VY ON-SHIFT STAFFING ANALYIS REPORT Function / Responsibility (Task) Analysis Template Event: # 1 Site: Vermont Yankee Position: Control Room Supervisor Line #: 8-10, 13 Function Responsibility (Task) Action Step Duration

1. Off-Site Notification 1.1 Complete the state notification 1.1.1 form using InForm. Retrieve Procedure EPAP-INFORM-10076, "InForm 12" Notification System".

1.1.2 3" Launch the InForm software.

1.1.3 Enter the required information on the Plant 1' 56" Information Tab.

1.1.4 Enter the required information on the Protective 8" Actions Tab.

1.1.5 19" Click on the "Show Notification Form" button and review the form for accuracy.

.. . ... for TAWK duration .. cletI'ý`notif6cadonrin

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2. State notification 2.1 Transmit the state notification 2.1.1 form using InForm Obtain verification, and click on the "Send Message" 8" button.

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a n*'fic ati*,*4.8

3. NRC Notification 3.1 Complete NRC event 3.1.1 notification form Retrieve VY APF 0156.01, "Event Notification 15" Worksheet."

3.1.2 Complete VY APF 0156.01, "Event Notification 15' 17" Worksheet," for the appropriate emergency event.

3.1.3 2' 59" Make telephone call to notify the NRC TA rao 'tifii*t- 8' .*

4. Event Mitigation 4.1 Assess and respond to plant 4.1.1 conditions Provide assistance to the Shift Manager in mitigating 7' 32' the event as directed.

A§ K duraotor 16mft. aIation T32

~, ~W TOTAL DURATION 4 Task Performer: Vince Roll Position: Control Room Supervisor Date: 2/20/14 Evaluator: Chuck Dissinqer Position: Senior Emeraency Planner Date: 2/20/14 VY Page 48

VY ON-SHIFT STAFFING ANALYIS REPORT B. Analysis #2 - Fuel Handling Accident TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #2 Fuel Handling Accident TASK 1: Complete the State Notification Form Using InForm JOB: Control Room Supervisor TASK 2: Transmit the State Notification Form Using InForm JOB: Control Room Supervisor TASK 3: Perform Off-Site Dose Assessment JOB: Control Room Supervisor TASK 4: Perform NRC Notification JOB: Control Room Supervisor TASK 5: Perform Event Mitigation JOB: Control Room Supervisor Page 49 vy VY Page 49

VY ON-SHIFT STAFFING ANALYIS REPORT PURPOSE:

Perform a Time Motion Study to evaluate whether the performance of notification and dose assessment actions assigned to the Control Room Supervisor are acceptable task overlaps to the Control Room Supervisor's primary emergency plan function of event mitigation.

After the dose assessment is complete, the Control Room Supervisor will formulate a Protective Action Recommendation (PAR) based on the dose assessment results.

NOTE:

The Time Motion Study should be completed in a simulator training scenario with a stack release (GE level release) to demonstrate dose assessment actions while the Shift Manager is demonstrating the Emergency Director function. Stack Release Rate, Wind Direction, Wind Speed, and Stability Class as determined by the Simulator Instructors or the EP Representative or Instructor to require a PAR based on dose assessment.

CONCLUSION:

The Time Motion Study demonstrated the Control Room Supervisor could perform the tasks of completing State, local and NRC notifications and dose assessment successfully, individually or in series, without impacting the ability of the CRS to remain in role providing support and oversight during the emergency.

LOCATION:

Simulator REQUIRED TOOLS/EQUIPMENT:

A. Attachment 9.5 of Procedure OP 3513, "Evaluation of Offsite Radiological Conditions" B. Procedure EPOP-PAR-351 1, "Off-Site Protective Action Recommendations" C. Stopwatch or watch to time actions Page 50 vy VY Page 50

Function / Responsibility (Task) Analysis Template Event: #_2 Site: Vermont Yankee Position: Control Room SuDervisor Line#: 8-10,12.13 Function Responsibility (Task) Action Step Duration

1. Off-Site Notification 1.1 Complete the state notification 1.1.1 form using InForm. Retrieve Procedure EPAP-INFORM-10076, "InForm 12" Notification System".

1.1.2 3" Launch the InForm software.

1.1.3 Enter the required information on the Plant 1' 56" Information Tab.

1.1.4 8"

Enter the required information on the Protective Actions Tab.

1.1.5 Click on the "Show Notification Form" button and 19" review the form for accuracy.

TAý~duatin~fr omplete notification formV 384

2. State notification 2.1 Transmit the state notification 2.1.1 form using InForm Obtain verification, and click on the "Send Message" 8" button.

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A durat~ onfr sae of cto

3. Dose Assessment 3.1 Perform Dose Assessment 3.1.1 and Protective using the Off-Site Dose Click the "ODPS" menu item on the RTIME menu bar Action Projection System per OP to access the "ODPS Menu" OR if the workstation has Recommendation 3513, Attachment 9.5 for a an ERFIS terminal keyboard, press the "ODPS" key.

stack release 3.1.2 Click on the "SOURCE TERM DATA" box to display screen.

3.1.3 Click the "PDPS" menu item on the RTIME menu bar 5" to access the "ODPS Menu" OR if the workstation has an ERFIS terminal keyboard, press the "ODPA" key.

3.1.4 Click on the "PROTECTIVE ACTION RECOMMENDATIONS LIVE STACK MR/HR" box to display screen.

4" 3.2 Formulate a PAR using 3.2.1 1' 06" Section 9.2 of EPOP-PAR- Use InForm to obtain the PAR VY Page 51

Task Performer: Vince Roll Position: Control Room SuDervisor Date: 2/20/14 Evaluator: Chuck Dissinqer Position: Senior Emeraencv Planner Date: 2/20/14 Page 52 Vy VY Page 52

VY ON-SHIFT STAFFING ANALYIS REPORT C. Analysis #3 - Aircraft Potential Threat TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #3 Aircraft Potential Threat TASK 1: Complete the State Notification Form Using InForm JOB: Control Room Supervisor TASK 2: Transmit the State Notification Form Using InForm JOB: Control Room Supervisor TASK 3: Perform NRC Notification JOB: Control Room Supervisor TASK 4: Perform Event Mitigation JOB: Control Room Supervisor Page 53 vy VY Page 53

PURPOSE:

Perform a Time Motion Study to evaluate whether the performance of NRC notification actions assigned to the Control Room Supervisor is an acceptable task overlap to the Control Room Supervisor's primary emergency plan function of event mitigation.

NOTE:

The Time Motion Study should be completed in a simulator training scenario to demonstrate notification actions while the Shift Manager is demonstrating the Emergency Director function.

CONCLUSION:

The Time Motion Study demonstrated the Control Room Supervisor could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the CRS to remain in role providing support and oversight during the emergency.

LOCATION:

Simulator REQUIRED TOOLS/EQUIPMENT:

A. Attachment 9.5 of Procedure OP 3513, "Evaluation of Offsite Radiological Conditions" B. Procedure EPOP-PAR-351 1, "Off-Site Protective Action Recommendations" C. Stopwatch or watch to time actions Page 54 vy VY Page 54

VY ON-SHIFT STAFFING ANALYIS REPORT Function / Responsibility (Task) Analysis Template Event: # 3 Site: Vermont Yankee Position: Control Room Supervisor Line # : 9, 13 Responsibility (Task) Action Step 1.1 Complete the state notification 1.1.1 form using InForm. Retrieve Procedure EPAP-INFORM-10076, "InForm Notification System".

Task Performer: Vince Roll Position: Control Room Supervisor Date: 2/20/14 Evaluator: Chuck Dissinaer Position: Senior Emeraencv Planner Date: 2/20/14 VY Page 55

VY ON-SHIFT STAFFING ANALYIS REPORT D. Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #4 Control Room Fire Requiring Evacuation and Maintain SFP Cooling TASK 1: Complete the State Notification Form Using InForm JOB: Control Room Supervisor TASK 2: Transmit the State Notification Form Using InForm JOB: Control Room Supervisor TASK 3: Perform NRC Notification JOB: Control Room Supervisor TASK 4: Perform Event Mitigation JOB: Control Room Supervisor Page 56 vy VY Page 56

VY ON-SHIFT STAFFING ANALYIS REPORT PURPOSE:

Perform a Time Motion Study to evaluate whether the performance of notification actions assigned to the Control Room Supervisor is an acceptable task overlap to the Control Room Supervisors primary emergency plan function of event mitigation.

NOTE:

The Time Motion Study should be completed in a simulator training scenario to demonstrate notification actions while the Shift Manager is demonstrating the Emergency Director function.

CONCLUSION:

The Time Motion Study demonstrated the Control Room Supervisor could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the CRS to remain in role providing support and oversight during the emergency.

LOCATION:

Simulator REQUIRED TOOLS/EQUIPMENT:

A. Attachment 9.5 of Procedure OP 3513, "Evaluation of Offsite Radiological Conditions" B. Procedure EPOP-PAR-351 1, "Off-Site Protective Action Recommendations" C. Stopwatch or watch to time actions Page 57 vy VY Page 57

VY ON-SHIFT STAFFING ANALYIS REPORT Function / Responsibility (Task) Analysis Template Event: #4 Site: Vermont Yankee Position: Control Room Supervisor Line #: 8-10, 13 I

Task Performer: Vince Roll Position: Control Room Supervisor Date: 2/20/14 Evaluator: Chuck Dissinaer Position: Senior Emergency Planner Date: 2/20/14 Page 58 VY VY Page 58

VY ON-SHIFT STAFFING ANALYIS REPORT E. Analysis #5 - General Emergency with Radioactive Release and PAR TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #5 General Emergency with Radioactive Release and PAR TASK 1: Complete the State Notification Form Using InForm JOB: Control Room Supervisor TASK 2: Transmit the State Notification Form Using InForm JOB: Control Room Supervisor TASK 3: Perform Off-Site Dose Assessment JOB: Control Room Supervisor TASK 4: Perform NRC Notification JOB: Control Room Supervisor TASK 5: Perform Event Mitigation JOB: Control Room Supervisor Page 59 vy VY Page S9

PURPOSE:

Perform a Time Motion Study to evaluate whether the performance of notification and dose assessment actions assigned to the Control Room Supervisor are acceptable task overlaps to the Control Room Supervisor's primary emergency plan function of event mitigation.

After the dose assessment is complete, the Control Room Supervisor will formulate a Protective Action Recommendation (PAR) based on the dose assessment results.

NOTE:

The Time Motion Study should be completed in a simulator training scenario with a stack release (GE level release) to demonstrate dose assessment actions while the Shift Manager is demonstrating the Emergency Director function. Stack Release Rate, Wind Direction, Wind Speed, and Stability Class as determined by the Simulator Instructors or the EP Representative or Instructor to require a PAR based on dose assessment.

CONCLUSION:

The Time Motion Study demonstrated the Control Room Supervisor could perform the tasks of completing State, local and NRC notifications and dose assessment successfully, individually or in series, without impacting the ability of the CRS to remain in role providing support and oversight during the emergency.

LOCATION:

Simulator REQUIRED TOOLS/EQUIPMENT:

A. Attachment 9.5 of Procedure OP 3513, "Evaluation of Offsite Radiological Conditions" B. Procedure EPOP-PAR-351 1, "Off-Site Protective Action Recommendations" C. Stopwatch or watch to time actions Page 60 VY vy Page 60

Function / Responsibility (Task) Analysis Template Event: # 5 Site: Vermont Yankee Position: Control Room Supervisor Line#: 8-10, 12. 13 Function Responsibility (Task) Action Step Duration

1. Off-Site Notification 1.1 Complete the state notification 1.1.1 form using InForm. Retrieve Procedure EPAP-INFORM-10076, "InForm 12" Notification System".

1.1.2 3" Launch the InForm software.

1.1.3 Enter the required information on the Plant 1'56" Information Tab.

1.1.4 Enter the required information on the Protective 8" Actions Tab.

1.1.5 Click on the "Show Notification Form" button and 19" review the form for accuracy.

TSK dration forcmltatWctoi~om ?8

2. State notification 2.1 Transmit the state notification 2.1.1 form using InForm Obtain verification, and click on the "Send Message" 8" button.

~TASK dufto f~or'staenigcation 8"

3. Dose Assessment 3.1 Perform Dose Assessment 3.1.1 and Protective using the Off-Site Dose Click the "ODPS" menu item on the RTIME menu bar Action Projection System per OP to access the "ODPS Menu" OR if the workstation has Recommendation 3513, Attachment 9.5 for a an ERFIS terminal keyboard, press the "ODPS" key.

stack release 3.1.2 Click on the "SOURCE TERM DATA" box to display 5' screen.

3.1.3 Click the "PDPS" menu item on the RTIME menu bar 5" to access the "ODPS Menu" OR if the workstation has an ERFIS terminal keyboard, press the "ODPA" key.

3.1.4 Click on the "PROTECTIVE ACTION RECOMMENDATIONS LIVE STACK MR/HR" box to display screen.

4" 3.2 Formulate a PAR using 3.2.1 1' 06" Section 9.2 of EPOP-PAR- Use InForm to obtain the PAR VY Page 61

3511 I 3.2.2 If available, a second individual should independently verify the PAR. The verification may be performed by 55" the individual who is approving the PAR (Shift Manaqer or Emerqencv Director)

4. NRC Notification 4.1 Complete NRC event 4.1.1 notification form Retrieve VY APF 0156.01, "Event Notification 15" Worksheet."

4.1.2 Complete VY APF 0156.01, "Event Notification 15' 17" Worksheet," for the appropriate emergency event.

4.1.3 2' 59" Make telephone call to notify the NRC I~~~ -nkiaW-A

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5. Event Mitigation 5.1 Assess and respond to plant 5.1.1 conditions Provide assistance to the Shift Manager in mitigating 7' 32' the event as directed.

Task Performer: Vince Roll Position: Control Room Supervisor Date: 2/20/14 Evaluator: Chuck Dissinqer Position: Senior Emergency Planner Date: 2/20/14 Page 62 VY VY Page 62

VY ON-SHIFT STAFFING ANALYIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures None X. REFERENCES

• Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

• NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities

• NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants

• Letter, Entergy Nuclear Operations, Inc. to USNRC "Request for Approval of Certified Fuel Handler Training Program," BVY 13-095, dated October 31, 2013 (ML13325B015)

• Letter, Entergy Nuclear Operations, Inc. to USNRC, 'Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition," BVY 13-096, dated October 31, 2013 (ML13316A004)

• NUREG-0654, Criteriafor Preparationand Evaluation of RadiologicalEmergency Response Plansand Preparednessin Supportof Nuclear Power Plants.

• VY Emergency Plan, Rev 54

• Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis Final Report, Rev. 0, December 19, 2012.

" Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis, Rev. 1, December 19, 2013.

XI. STAFFING ANALYIS TEAM The staffing analysis team consisted of plant and Entergy Corporate staff representing the following departments / organizations:

• Fleet Emergency Preparedness Project Management

" Operations

" Training

• Security

• Chemistry

• Radiation Protection

• Regulatory Assurance

" Emergency Planning Page 63 vy VY Page 63

BVY 14-018 Docket 50-271 Attachment 5 Vermont Yankee Nuclear Power Station ERO Task Analysis

BVY 14-018 Docket 50-271 Attachment 6 Vermont Yankee Nuclear Power Station List of Regulatory Commitments

BVY 14-018 / Attachment 6 / page 1 of 1 List of Regulatory Commitments This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

TYPE (Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION DATE COMMITMENT ACTION COMPLIANCE (If Required)

Revise applicable fuel handling procedures x Prior to permanent to require that a Chemistry Technician be removal of fuel from on-site or the radiation monitor listed in the the VY reactor gaseous effluent EALs is in service as a vessel prerequisite to handling or moving spent fuel.