BVY 15-003, Entergy Answer Opposing State Appeal - Vermont Yankee Nuclear Power Station - Emergency Plan Change, Revision 55

Entergy Answer Opposing State Appeal - Vermont Yankee Nuclear Power Station - Emergency Plan Change, Revision 55

ML15079A422
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png (DPR-028)
Issue date:	02/23/2015
From:	Mckenney M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
SECY RAS
Shared Package
ML15079A421	List: BVY 15-003, Entergy Answer Opposing State Appeal - Vermont Yankee Nuclear Power Station - Emergency Plan Change, Revision 55 ML15079A423
References
50-271-LA, ASLBP 15-934-01-LA- BD01, BVY 15-003, RAS 27403
Download: ML15079A422 (111)

Text

• -w-. Entergy BVY 15-003 February 23, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Emergency Plan Change, Revision 55 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28 Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 258 4183 Michael P. McKenney Emergency Planning Manager

REFERENCE:

Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License RE: Changes to the Emergency Plan {TAC NO.

MF3668,)" dated February 4, 2015

Dear Sir or Madam:

In accordance with 10 CFR 50.54(q) Entergy Nuclear Operations, Inc. is providing Revision 55 of the Vermont Yankee Nuclear Power Station Emergency Plan (Plan) as an attachment to this letter. This revision of the Plan incorporates changes approved by the NRC in Reference 1. This revision also includes several changes that were evaluated pursuant to 10 CFR 50.54{q)(3) that were determined not to require prior NRC approval. Included with this revision is a description of the changes and the 10 CFR 50.54(q) Screening and Evaluation Forms for those changes performed pursuant to 10 CFR 50.54(q)(3).

There are no new regulatory commitments contained in this submittal.

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

Sincerely,

BVY 15-003/ Page 2 of 2

Attachment:

Emergency Plan Change, Revision 55 cc:

Mr. Daniel H. Dorman Regional Administrator, Region 1 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 Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd.

Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601 Vermont Yankee Nuclear Power Station Emergency Plan Change, Revision 55 BVY 15-003 Docket No. 50-271

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 1 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

On 9/23/13, Entergy Vermont Yankee notified the NRC by letter BVY 13-079 of the decision to permanently cease power operations in the 4th quarter of 2014.This letter acknowledges that the Vermont Yankee 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel after the end of the operating cycle.

The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018).

These changes were approved by the NRC upon issuance of License Amendment 261. (Change summary attached)

The Emergency Plan and the following documents have been revised to incorporate the approved License Amendment for the SAFSTOR Emergency Plan and Emergency Response Organization (ERO). See attached change summaries for each document.

Cancel V-EN-TQ-110, Emergency Response Organization, Rev 11 and V-EN-TQ-110-01, Fleet Eplan Training Course Summary, Rev 2 to the SAFSTOR Emergency Planning Training Program Description EPOP-TSC-3542, Operation of the Technical Support Center (TSC), Rev 02 EPOP-OSC-3544, Operation of the Operations Support Center (OSC), Rev 01 EPOP-EOF-3546, Emergency Operations Facility/Recovery Center (EOF/RC), Rev 03 EPOP-JIC-3550, Activation and Operation of the Joint Information Center, Rev 01 EPOP-3551, Operation of the Joint Information Center when the Alternate Joint Information Center is Activated, Rev 01 EPOP-3552, Activation and Operation of the Alternate Joint Information Center, Rev 01 V-EN-EP-801, Emergency Response Organization AP 0894, Staffing Limits Part II. Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If YES, identify bounding source document number/approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:

YES 50.54(q)(3)

Evaluation is NOT required.

Enter justification below and complete Part VI.

NO Continue to next part Justification:

Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). These changes were approved by the NRC upon issuance of License Amendment 261. No further evaluation required.

Bounding document attached (optional)

References:

BVY 13-079; BVY 14-018

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 2 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3 Part III. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-100)

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

Screening.

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

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

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

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

CONTROLLING CHANGE PROCESSES 10CFR50.54(q)

Part IV. Editorial Change Is this activity an editorial or typographical change such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?

Justification:

YES 50.54(q)(3)

Evaluation is NOT required.

Enter justification and complete Part VI.

NO Continue to next part Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

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

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan. [1]

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

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

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

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

7. A standard scheme of emergency classification and action levels is in use. [4]

8. Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

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

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

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

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 3 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

26. Identified weaknesses are corrected. [14]

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

28. Responsibility for emergency plan development and review is established. [16]

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

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 4 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3 APPLICABILITY CONCLUSION If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Part VI. Signatures:

Preparer Name (Print)

Justine Anderson Preparer Signature Date:

2/4/15 (Optional) Reviewer Name (Print)

Reviewer Signature Date:

Reviewer Name (Print)

Tom Sowdon Nuclear EP Project Manager Reviewer Signature Date:

2/4/15

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 5 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3 Emergency Planning Training Program Description Developed training for new SAFSTOR organization to match the staffing changes in BVY 14-018 EPOP-TSC-3542, Operation of the Technical Support Center (TSC), Rev 02 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

TSC Manager Reactor Engineer Manpower and Planning Liaison TSC Communicator TSC Engineer IT Specialist EPOP-OSC-3544, Operation of the Operations Support Center (OSC), Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

Operations Support I&C/Electrical Coordinator Mechanical Coordinator Rad/Chem Coordinator Work Control Coordinator OSC Log Keeper EPOP-EOF-3546, Emergency Operations Facility/Recovery Center (EOF/RC), Rev 03 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

EOF Manager EOF Communicator Public Information Liaison Emergency Planning Coordinator IT Specialist EOF Log Keeper EPOP-JIC-3550, Activation and Operation of the Joint Information Center, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

Information Coordinator Press Release Writer Logistics Coordinator Technical Assistant JIC Log Keeper Inquiry Response Coordinator Media Monitor/Status Phone Recorder Credentialing

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 6 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3 EPOP-3551, Operation of the Joint Information Center when the Alternate Joint Information Center is Activated, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

Information Coordinator Press Release Writer Logistics Coordinator Technical Assistant Inquiry Response Coordinator Media Monitor/Status Phone Recorder EPOP-3552, Activation and Operation of the Alternate Joint Information Center, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

Logistics Coordinator Credentialing JIC Log Keeper V-EN-EP-801, Emergency Response Organization Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

TSC Manager Reactor Engineer Manpower and Planning Liaison TSC Communicator TSC Engineer IT Specialist Operations Support I&C/Electrical Coordinator Mechanical Coordinator Rad/Chem Coordinator Work Control Coordinator OSC Log Keeper EOF Manager EOF Communicator Public Information Liaison Emergency Planning Coordinator IT Specialist EOF Log Keeper Information Coordinator Press Release Writer Logistics Coordinator Technical Assistant JIC Log Keeper Inquiry Response Coordinator Media Monitor/Status Phone Recorder Credentialing Removed all information pertaining to other Entergy sites

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 7 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee

Title:

Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)

EN-EP-305 REV 3 AP 0894, Staffing Limits Revised on shift staffing to match the License Amendment 261 from the NRC

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 1 OF 52 EN-LI-100 REV. 16 I. OVERVIEW PAD Rev. #: 0 Facility: Vermont Yankee Proposed Activity / Document: Emergency Plan Change/Rev. #: 55 Description of Proposed Activity:

The proposed changes to the Emergency Plan are shown in a table following section VIII.

This PAD covers the changes to the Emergency Plan approved by the NRC in License Amendment 261 (Ref: NVY 15-010) to reduce staffing for the Emergency Response Organization. The changes to staffing levels approved by License Amendment 261 include:

Table 8.4, Minimum Staffing Requirements for the ENVY ERO Table 8.3, "A Summary of Off-site 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" Table 9.1, "Vermont Yankee Emergency Response" All other changes to reflect a permanently defueled facility were performed under the 10CFR50.54(q) process.

II.

DOCUMENT REVIEW Provide the requested information for each item below.

1.

For documents available electronically:

a.

List search engine or documents searched, and keywords used:

Documents Searched: UFSAR, Emergency Plan Keywords used: InForm, Notification System, Utility Microwave, Emergency Response Data System, ERDS, Medical, URI, METPAC, Dose Assessment

b.

List relevant sections of controlled electronic documents reviewed:

UFSAR - Section 7.15, Process Computer System; Section 13.6, Emergency Plan Emergency Plan - Entire document

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 2 OF 52 EN-LI-100 REV. 16 2.

Documents reviewed manually (hardcopy):

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

3.

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

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

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 3 OF 52 EN-LI-100 REV. 16 III.

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

PROCESS (Regulations / Procedures)

YES NO REVIEW RESULTS Chemistry / Effluents Radwaste / Process Control Program (PCP)

(EN-RW-105 or contact the Radiation Protection Dept.)

Radiation Protection / ALARA (10 CFR 20 / EN-RP-110 or contact the Radiation Protection Dept.)

Inservice Inspection Program (10 CFR 50.55a / EN-DC-120, -351)

Inservice Testing Program (10 CFR 50.55a / EN-DC-332)

Maintenance Rule Program (10 CFR 50.65 / EN-DC-203, -204, -205, -206,

-207)

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

PROCESS (Regulations/Procedures)

YES NO N/A REVIEW RESULTS Flex Program (NRC Order EA-12-49/FLEX Program) (10CFR50.59 /

Contact Design Engineering)

NOTE: The date for individual Site Implementation of the FLEX Program is not the same for all sites. All sites are required to implement a FLEX program per NRC Order EA-12-49. N/A may be used for this process by sites that have not completed implementation of a FLEX program. Contact Design Engineering if further assistance is needed.

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

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 4 OF 52 EN-LI-100 REV. 16 IV.

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

LICENSING BASIS DOCUMENTS (Regulations / Procedures)

YES NO REVIEW RESULTS OR SECTIONS AFFECTED OR LBDCR #

Quality Assurance Program Manual (QAPM)

(10 CFR 50.54(a) / EN-QV-104)

Fire Protection Program (FPP) [includes the Fire Safety Analysis/Fire Hazards Analysis (FSA/FHA)]

OL Condition, 10 CFR 50.48 / EN-DC-128)

Emergency Plan (10 CFR 50.54(q) / EN-EP-305)

Screened IAW EN-EP-305 Environmental Protection Plan (Appendix B of the OL, Environmental Evaluation / EN-EV-115, EN-EV-117, EN-LI-103)

No EPP at VY Security Plan and Cyber Security Plan

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

Operating License (OL) / Technical Specifications (TS)

(10 CFR 50.90 / EN-LI-103)

TS Bases (10 CFR 50.59 / EN-LI-100 / EN-LI-101)

Technical Requirements Manual (TRM) (including TRM Bases)

(10 CFR 50.59 / EN-LI-100 / EN-LI-101)

Core Operating Limits Report (COLR), and Pressure and Temperature Limits Report (PTLR) (TS Administrative Controls, EN-LI-113, EN-LI-100, EN-LI-101)

Offsite Dose Calculation Manual (ODCM)

(TS Administrative Controls or 10 CFR 50.59 / EN-LI-113 or EN-LI-100 /

EN-LI-101)

Updated Final Safety Analysis Report (UFSAR)

(10 CFR 50.71(e) / EN-LI-113, EN-LI-100, EN-LI-101)

UFSAR markups to reflect termination of the Emergency Response Data System have been submitted to Licensing Storage Cask Certificate of Compliance (10 CFR 72.244 / EN-LI-113)

Cask FSAR (CFSAR) (including the CTS Bases)

(10 CFR 72.70 or 72.248 / EN-LI-113, EN-LI-100,EN-LI-112) 10 CFR 72.212 Evaluation Report (212 Report)

(10 CFR 72.48 / EN-LI-100, EN-LI-112)

NRC Orders (10 CFR 50.90 / EN-LI-103 or as directed by the Order)

NRC Commitments and Obligations (EN-LI-110)

Site Specific CFR Exemption (10 CFR 50.12, 10 CFR 55.11, 10 CFR 55.13, 10 CFR 72.7)

• Contact the site Regulatory Assurance Department if needed.

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

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 5 OF 52 EN-LI-100 REV. 16 V.

10 CFR 50.59 / 10 CFR 72.48 APPLICABILITY Can the proposed activity be dispositioned by one of the following criteria? Check the appropriate box (if any).

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

The NRC has approved the proposed activity or portions thereof or a license amendment being reviewed by the NRC addresses the proposed activity. Reference the approval document: Licensing Amendment 261 The proposed activity is controlled by one or more specific regulations.

Examples of programs controlled by specific regulations are:

Maintenance Rule (50.65) (EN-DC-203)

Quality Assurance Program (10 CFR 50 Appendix B) (EN-QV-104)

Security Plan [50.54(p)] (EN-NS-210)

Emergency Plan [50.54(q)] (EN-EP-305)

Fire Protection Program (operating license condition)

Inservice Inspection Program (50.55a) (EN-DC-351)

Inservice Testing Program (50.55a) (EN-EC-332 See NEI 96-07 Section 4.1 for additional guidance on specific regulations.

Reference the controlling specific regulation(s): 10CFR50.54(q)

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

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

Changes to the IPEC Unit 1 Decommissioning Plan are to be evaluated in accordance with the 50.59 process, as allowed by the NRC in a letter to IPEC dated January 31, 1996. [Merlin Document ID:

RA-96-014]

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 6 OF 52 EN-LI-100 REV. 16 VI.

50.59 / 72.48 SCREENING REVIEW (All proposed activities should be evaluated to determine if 50.59, 72.48 or both apply, check the boxes as appropriate)

VI.A 50.59 SCREENING 10 CFR 50.59 applies and screening criteria are met. Document the basis for screening criteria met in section VI. C, then proceed to section VII. [10 CFR 50.59(c)(1)]

The proposed activity meets all of the following criteria:

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

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

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

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

IF 10 CFR 50.59 applies, but the proposed activity does not meet the applicable criteria, THEN perform a 50.59 Evaluation in accordance with EN-LI-101, attach a copy of the Evaluation to this form, and proceed to Section VII.

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

The proposed activity meets all of the following criteria:

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

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

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

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

IF 10 CFR 72.48 applies, but the proposed activity does not meet the applicable criteria, THEN perform a 72.48 Evaluation in accordance with EN-LI-112, attach a copy of the Evaluation to this form, and proceed to Section VII.

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 7 OF 52 EN-LI-100 REV. 16 VI.B BASIS Provide a clear, concise basis for determining the proposed activity may be screened out such that a third-party reviewer can reach the same conclusions. Identify the relevant design function, as appropriate. Refer to NEI 96-07 Section 4.2 for guidance. Refer to NEI 12-06 Section 11.4, regarding FLEX. Provide supporting documentation or references as appropriate.

VII. REGULATORY REVIEW

SUMMARY

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

The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). These changes were approved by the NRC upon issuance of License Amendment 261. No additional evaluation is required for these changes.

Other changes to the Emergency Plan to reflect the permanently defueled condition are evaluated pursuant to 10 CFR 50.54(q) in accordance with EN-EP-305.

VII.B CONCLUSIONS 1.

Is a change to an LBD being initiated?

Yes IF Yes, THEN enter the appropriate change control process and include this form with the change package. (LBDCR LIC 14-14)

No 2.

Is a 10 CFR 50.59 Evaluation required?

Yes IF Yes, THEN complete a 50.59 Evaluation in accordance with EN-LI-101 and attach a copy to the change activity.

No 3.

Is a 10 CFR 72.48 Evaluation required?

Yes IF Yes, THEN complete a 72.48 Evaluation in accordance with EN-LI-112 and attach a copy to the change activity.

No

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 8 OF 52 EN-LI-100 REV. 16 VIII.

SIGNATURES 1 Preparer:

Justine Anderson/

/ENVY/ Eplan/ 1/16/15 Name (print) / Signature / Company / Department / Date Reviewer:

Phil Couture/ Approved per telecon /ENVY/ Licensing/ 2/4/15 Name (print) / Signature / Company / Department / Date Process Applicability Exclusion Site Procedure N/A Champion or Owner:

Name (print) / Signature / Company / Department / Date Upon completion, forward this PAD form to the appropriate organization for record storage. If the PAD form is part of a process that requires transmittal of documentation, including PAD forms, for record storage, then the PAD form need not be forwarded separately.

1 The printed name, company, department, and date must be included on the form. Signatures may be obtained via electronic processes (e.g., PCRS, ER processes, Asset Suite signature), manual methods (e.g.,

ink signature), e-mail, or telecommunication. If using an e-mail, attach it to this form.

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 9 OF 52 EN-LI-100 REV. 16 Emergency Plan Section Before (Rev. 54)

After Reason for Change Table of Contents Updated page numbers and Section headings to reflect changes described below, including updated page numbers and deletion of Section 6.2.5 (Post Accident Sampling) and Section 7.10 (Emergency Response Data System).

Editorial revision to reflect changes described below, including updated page numbers and deletion of Section 6.2.5 (Post Accident Sampling) and Section 7.10 (Emergency Response Data System).

Table of Contents -

Appendices Appendix C Initial Offsite Dose Rate Estimate (Deleted)

VY will no longer be an operating nuclear power plant. Appendix C is no longer applicable because it is based on the isotopic mix for a Loss of Coolant Accident (LOCA).

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

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

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

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 10 OF 52 EN-LI-100 REV. 16 Emergency Plan Section Before (Rev. 54)

After Reason for Change structure.

Table of Contents - List of Figures Figure 8.4 Operations Support Center Emergency Organization (Deleted)

ERO Staffing changes result in one 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 Operations Facility Organization Figure 8.5 Defueled Emergency Operations Facility Organization VY will no longer be an operating nuclear power plant. The title change reflects the permanently defueled organizational structure.

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

Table of Contents - List of Figures Figure 10.1 Vermont Yankee Emergency Dose Rate Nomogram (Deleted)

VY will no longer be an operating nuclear power plant. Figure 10.1 is no longer applicable because it is based on the isotopic mix for a LOCA.

Section 2.0 - Definition of Alert Alert - Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel Alert - Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel Editorial revision to reflect definition in NEI 99-01, Rev.

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After Reason for Change or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Section 2.0 - Definition of Assessment Actions Assessment Actions - Those actions which are take to effectively define the emergency situation necessary for decisions on specific emergency measures.

Assessment Actions - Those actions which are taken to effectively define the emergency situation necessary for decisions on specific emergency measures.

Editorial revision to correct grammatical error Section 2.0 - Definition of General Emergency General Emergency - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

General Emergency - Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Editorial revision to reflect definition in NEI 99-01, Rev.

5 Section 2.0 - Definition of Hostile Action Hostile Action - An act toward an NPP or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other Hostile Action - An act toward an NPP or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other Editorial revision to reflect definition in NEI 99-01, Rev.

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After Reason for Change devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area).

devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area).

Section 2.0 - Definition of Notification of Unusual Event Notification of Unusual Event

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

Notification of Unusual Event

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

Editorial revision to reflect definition in NEI 99-01, Rev.

5 Section 2.0 - Definition of Site Area Emergency Site Area Emergency - Events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that Site Area Emergency - Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that Editorial revision to reflect definition in NEI 99-01, Rev.

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After Reason for Change could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

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

Section 3.2 - 1st Paragraph, Item 5

5) Notify state authorities in Vermont, New Hampshire and Massachusetts using the Emergency Notification System.

5) Notify state authorities in Vermont, New Hampshire and Massachusetts using the InForm Notification System.

InForm added to the Emergency Plan in Rev. 54.

Section 3.2 - 1st Paragraph, Item 7

7) Use the emergency notification system to notify appropriate personnel as set forth in Figure 9.1 and Table 9.1.

7) Use the notification plan to notify appropriate personnel as set forth in Figure 9.1 and Table 9.1.

The Emergency Notification System is a formal system used to notify the NRC during an emergency. The generic use of emergency notification system in Step 7 can be confusing and is meant only to direct the communicator to use the notification plan set forth in Figure 9.1 and Table 9.1 of the Emergency Plan and not the Emergency Notification System. Figure 9.1 is entitled Notification Plan and identifies the methods used to notify various offsite agencies.

Section 4.1 Vermont Yankee Nuclear Power Station is located on the west bank of the Connecticut River Vermont Yankee Nuclear Power Station is located on the west bank of the Connecticut River VY will no longer be an operating nuclear power plant. The Site Description

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After Reason for Change immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. The Vermont Yankee Nuclear Power Station is a boiling water reactor having a thermal rated power of 1912 MWt. The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Entergy, with the exception of a narrow strip of land between the Connecticut River and the Vermont Yankee property for which it has perpetual rights and easements from the owner, New England Power Company.

immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. The Vermont Yankee Nuclear Power Station ceased 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 January 12, 2015, ENO submitted a certification that a determination to permanently cease power operations was made on December 29, 2014, pursuant to 10 CFR 50.82(a)(1)(i). 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 and placed in the Spent Fuel Pool. Upon docketing of these certifications, the 10 CFR Part 50 license for has been revised to indicate the permanently shutdown and defueled condition.

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After Reason for Change 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.

Section 4.2 - 2nd Paragraph The nearest house is 1,300 feet from the Reactor Building and is one of several west of the site.

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

The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500 feet from the Reactor Building. The nearest hospital, Brattleboro Memorial, is approximately five (5) miles north-northwest from the site. The nearest dairy farm is approximately 1/2-mile northwest of the site. Additional dairy farms are located within a 5-mile radius of the plant. A nursing home is located 2 miles Editorial. The Hinsdale Raceway no longer operates and reference is removed from the Emergency Plan.

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

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.

Section 5.1 - 1st Paragraph Notification of Unusual Event Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

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

Editorial revision to reflect definition in NEI 99-01, Rev.

5 Section 5.1 - 2nd Paragraph Notification of Unusual Event conditions do not cause serious damage to the plant and may not require a change in operational status. The purpose of the Notification of Unusual Event declaration is to: 1) ensure that the first step in any response later found to be necessary has Notification of Unusual Event conditions do not cause serious damage to the plant. The purpose of the Notification of Unusual Event declaration is to:

1) ensure that the first step in any response later found to be necessary has been carried out;

2) bring the operating staff to a VY will no longer be an operating nuclear power plant. A change in operational status is not a consideration due to the permanently shutdown and defueled plant condition.

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After Reason for Change been carried out; 2) bring the operating staff to a state of readiness; and 3) ensure that appropriate offsite notifications have been made in the event that additional support is required.

state of readiness; and 3) ensure that appropriate offsite notifications have been made in the event that additional support is required.

Section 5.2 - 1st Paragraph Alert Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Editorial revision to reflect definition in NEI 99-01, Rev.

5 Section 5.3 - 1st Paragraph Site Area Emergency Events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to Site Area Emergency Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to Editorial revision to reflect definition in NEI 99-01, Rev.

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After Reason for Change equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Section 5.4 - 1st Paragraph General Emergency Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

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

General Emergency Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

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

Editorial revision to reflect definition in NEI 99-01, Rev.

5 Figure 6.2 See After Column Replaced Comm. Room with Main TSC Area Editorial revision to accurately depict TSC layout.

Figure 6.3 See After Column Deleted Radiation Protection Offices Changed OSC Communication Center to OSC Manager and Briefing Room Deleted Chemistry Offices Changed Briefing Room to Rad Protection Editorial revision to accurately depict OSC layout.

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After Reason for Change Changed Rad Prot to NCO Room Changed AO Room to NCO Room Figure 6.4 See After Column Deleted HVAC Room Added NRC Room Changed Chemistry &

Sample Anal. Lab to Chemistry and Sample Analysis Laboratory Changed OSMT Communication Area to Monitoring Team Communication Area Changed Rad Assessment to Rad Assessment Area Deleted Field Team Coordination Deleted Alternate Facility Deleted Warehouse Deleted Decon Area Combined Security and Administration and Logistics into Security &

Admin/Logistics Editorial revision to accurately depict EOF/RC layout.

Section 7.3 The Utility Microwave and Radio Systems are located in the Control Room. The Utility Microwave is a line-of-sight dedicated system used to notify system load dispatchers of emergency conditions at the plant. The telephone has The Utility Microwave and Radio Systems are located in the Control Room. In the event that communications fail with the NRC due to loss of the commercial telephone system, load dispatchers are advised that Vermont Yankee will use the VY will no longer be an operating nuclear power plant. There will no longer be a need to notify system load dispatchers of emergency conditions at the plant because the potential to disrupt the power grid will

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After Reason for Change buttons marked for each load dispatcher. By pushing one of the buttons on the telephone, it rings automatically at the selected location. In the event that communications fail with the NRC due to loss of the commercial telephone system, the load dispatchers are advised that Vermont Yankee will use the Utility Microwave System to provide updates of plant conditions to NRC Region I.

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

Utility Microwave System to provide updates of plant conditions to NRC Region I.

no longer exist.

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

Core and coolant system

data, Containment building Deleted VY will no longer be an operating nuclear power plant.Section VI.1 of Appendix E to 10 CFR Part 50 indicates that ERDS is not applicable to nuclear power facilities that are shut down. Based on the permanently defueled status, this system is no longer necessary to transmit safety system parameter data to the NRC.

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After Reason for Change

data, Radioactivity release data, and Site meteorological data.

Vermont Yankee maintains a continuous ERDS connection with the NRC Operations Center.

NRC Memorandum from the Director, Division of Preparedness and Response (NSIR) to Regions (Division of Reactor Projects) clarifies the requirements for maintenance and use of ERDS by licensees who have submitted certification of permanent cessation of operations pursuant to Section 50.82, Termination of Licenses, in Part 50, Domestic Licensing of Production and Utilization Facilities, of Title 10 of the Code of Federal Regulations, (10 CFR Part 50). This memorandum is publicly available in ADAMS (ML14099A520).

Table 7.1:

State Police (VT, NH, MA) from CR State Police (VT, NH, MA) from EOF State EOCs (VT, NH, MA)

State EOCs (VT, NH, MA) from EOF 1, 2 1, 2 1, 2, 9 1, 2, 9, 10 1, 2, 11 1, 2, 11 1, 2, 9, 11 1, 2, 9, 10, 11 Add InForm to Table Key as #11 InForm added to the Emergency Plan in Rev. 54.

Section 8.1 - 2nd Paragraph During normal operations, the minimum staff on duty at the The minimum staff on duty at the plant during all shifts consists of VY will no longer be an operating nuclear power

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After Reason for Change plant during all shifts consists of one (1) Shift Manager, one (1)

Control Room Supervisor, two (2) Control Room Operators, six (6) Auxiliary Operators, one (1)

Shift Technical Advisor, one (1)

Radiation Protection Technician, one (1) Chemistry Technician and security personnel as indicated in Figure 8.1. The responsibility for determining the status of the plant in an emergency is assigned to the Shift Manager or, in his absence from the Control Room, to the Control Room Supervisor who has the authority and responsibility to immediately initiate any emergency actions, including emergency classification and notification.

Additional personnel are available on an on-call basis to respond to plant emergencies.

Corrective action and repair, as outlined in Table 8.4, is performed by Operations staff on-shift until supplemented by additional ERO staff.

one (1) Shift Manager, one (1)

Certified Fuel Handler (CFH),

three (3) Non-Certified Operators (NCO), one (1) Radiation Protection 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 CFH 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.

plant. The following on-shift positions will be eliminated:

Shift Technical Advisor (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 one (1) Shift Manager (SM), one (1)

Certified Fuel Handler (CFH) and three (3) Non-Certified Operators (NCOs).

Title changes for the CRS to CFH and the AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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After Reason for Change 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.

Section 8.2 - 2nd Paragraph 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.

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 on-shift 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.

Editorial change from onshift to on-shift Section 8.2 - 5th Paragraph In emergency situations, the Shift Manager, Emergency Plant Manager, or OSC Manager can In emergency situations, the Shift Manager, Emergency Plant Manager, or OSC Manager can VY will no longer be an operating nuclear power plant and emplacement or

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After Reason for Change authorize actions, without following the complete work order process, if these actions prevent the following:

Loss of important equipment, Personnel injury, or Plant trip.

authorize actions, without following the complete work order process, if these actions prevent the following:

Loss of important equipment, or Personnel injury.

retention of fuel into the reactor vessel will no longer be authorized. Therefore a plant trip will no longer be applicable.

Section 8.2.2 - 1st Paragraph, Item 5

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

5. Develop guidance for plant shift operations concerning plant protection; VY will no longer be an operating nuclear power plant and emplacement or retention of fuel into the reactor vessel will no longer be authorized. Therefore, the need for the Emergency Plant Managers responsibilities to include protection of the reactor core is no longer applicable.

Section 8.2.2 - 2nd Paragraph 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 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 VY will no longer be an operating nuclear power plant and emplacement or retention of fuel into the reactor vessel will no longer be authorized. Therefore, the need to maintain a Reactor Engineer in the TSC is no longer applicable.

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After Reason for Change Reactor Engineering Engineering Chemistry (in the OSC)

Radiation Protection Security (stationed at the off site command post)

Engineering Chemistry Radiation Protection Security (stationed at the off site command post)

Section 8.2.4 EOF Manager Deleted entire section The EOF Manager position will not exist in the Permanently Defueled ERO.

Duties and responsibilities will be transferred to remaining positions within the EOF.

Section 8.2.10 During implementation of Severe Accident Management (SAM),

the senior licensed individual in the TSC will assume the role of Decision Maker as defined in the SAM Guideline.

During implementation of Severe Accident Management (SAM),

the Operations Coordinator in the TSC will assume the role of Decision Maker as defined in plant procedures.

EPOP-TSC-3542 states that the Operations Coordinator in the TSC assumes the duty of SAM Decision Maker.

Table 8.3, Page 2 of 3 Each State Health representative at the EOF/RC will request monitoring updates from the EOF Manager.

Each State Health representative at the EOF/RC will request monitoring updates from the Lead Offsite Liaison.

The EOF Manager position will not exist in the Permanently Defueled ERO.

Duties and responsibilities will be transferred to remaining positions within the EOF.

Table 8.3, Page 3 of 3 The Public Information Liaison at the EOF/RC relays accident status reports to the Joint Information Center.

The Technical Advisor at the EOF/RC relays accident status reports to the Joint Information Center.

The position of Public Information Liaison will not exist in the Permanently Defueled Emergency Response Organization

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After Reason for Change (ERO). Duties and responsibilities will be transferred to the Technical Advisor position.

Table 8.4 - Page 1 of 2, Functional Area - Plant Operations & Assessment of Operational Aspects VY will no longer be an operating nuclear power plant. The following on-shift positions will be 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)

CFH and three (3) NCOs.

Title changes for the CRS to CFH and AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was

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After Reason for Change approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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 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 Area -

Notification/Communication; Major Tasks - Notify Licensee, State, local and federal personnel & maintain communication VY will no longer be an operating nuclear power plant. The STA position will be eliminated.

Following permanent cessation of operations, the Chemistry Technician Position will not be

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After Reason for Change 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 was dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4 - Page 1 of 2; Functional Area -

Radiological Accident Assessment and Support of Operational Accident VY will no longer be an operating nuclear power plant. The STA and on-shift Chemistry Tech positions

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After Reason for Change Assessment; Major Tasks -

Offsite Dose Assessment will be eliminated.

STA assignments in this functional 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 was dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4 - Page 1 of 2; Functional Area -

Radiological Accident This change does not represent a change to the number of on-shift RP

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After Reason for Change Assessment and Support of Operational Accident Assessment; Major Tasks -

Onsite (out of plant)

Technicians. The number of on-shift RP Technicians remains one (1). The change is intended to clarify VYs RP Technician duties during an emergency, consistent with Table B-1 of NUREG-0654.

Table B-1 of NUREG-0654 does not identify an on-shift position responsible for onsite (out of plant) surveys. During the initial stages of an emergency, the on-shift RP Technician will be assigned to the most critical tasks during the emergency response. VY maintains the capability to augment on-shift staff with field monitoring teams to perform this task within 30 minutes of notification of an emergency declaration.

Table 8.4 - Page 1 of 2; Functional Area -

Radiological Accident Assessment and Support of Operational Accident Assessment; Major Tasks -

Chemistry/Radiochemistry VY will no longer be an operating nuclear power plant. The on-shift Chemistry Tech position will be eliminated.

Removal of the on-shift Chemistry Tech position has been evaluated in the VY analysis of proposed post-shutdown on-shift

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After Reason for Change staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Table 8.4 - Page 1 of 2; Functional Area - Plant System Engineering; Major Tasks - Shift Technical Advisor and Core Thermal Hydraulics VY will no longer be an operating nuclear power plant. The STA position will be eliminated.

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 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 1 of 2; Functional Area - Repair &

Corrective Actions; Major Tasks - Mechanical Maintenance The Defueled Organization contains three (3) NCOs on-shift. This on-shift complement has been evaluated in the VY analysis of proposed post-shutdown

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After Reason for Change on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Title changes for the AO to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4 - Page 1 of 2; Functional Area - Repair &

Corrective Actions; Major Tasks - Rad Waste Operator The CRO position is eliminated in the post-shutdown condition. The Defueled Organization consists of three (3) 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

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After Reason for Change condition.

Title changes for the AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4 - Page 1 of 2; Functional Area - Repair &

Corrective Actions; Major Tasks - Electrical Maintenance/Instrumentation

& Control Technician The Defueled Organization consists of three (3) 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 to NCO was dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced

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After Reason for Change references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4 - Page 2 of 2; Functional Area - Protective Actions (In Plant); Major Tasks - Radiation Protection, access control, HP, coverage for repair, corrective actions, search &

rescue, first aid & firefighting, personnel monitoring, dosimetry The Defueled Organization consists of three (3) 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 to NCO was dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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After Reason for Change Table 8.4, Note ****

May be performed by engineering aide to Shift Manager (STA for ENVY)

Deleted VY will no longer be an operating nuclear power plant. The STA position will be eliminated. STA oversight and technical knowledge 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.

Table 8.4, Note 1 AP 0894 specifies minimum shift staffing requirements. FB requires 5 persons per TRM and the Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis. The staffing analysis is maintained as a controlled document and is effective 30 days after OSRC approval. STA and Chemistry Tech must be available within 10 minutes to the Control Room. VY letter to NRC dated 4/14/1981 (FVY 81-

65) establishing position. VY letter to NRC 6/22/1982 (FVY 82-75) Supplement -NUREG 0737 Item III.A.1.2 on training of 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. The staffing analysis was evaluated to reflect VYs permanently shutdown and defueled conditions, including the on-shift staff composition and revised accident analyses.

The Defueled on-shift staffing 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.

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After Reason for Change 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 features for dose rate and total dose monitoring. AOs are trained to self-monitor in an emergency.

All NCOs use digital dosimeters with features for dose rate and total dose monitoring. NCOs are trained to self-monitor in an emergency.

Title changes for the AOs and CROs to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4, Note 3 ENVY has designated pager holders who staff positions required to meet minimum staffing to activate TSC, OSC and EOF (see E Plan Figures 8.3 through 8.5). There are a minimum of 4 persons per position (4 teams who rotate duty). However, all persons on 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 The Defueled Organization will consist of fewer than 4 teams rotating ERO duty.

Additional changes to this note are editorial to remove references to pagers and pager holders.

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After Reason for Change teams are expected to respond.

In addition, all other ERO personnel not on pagers are notified by the emergency call-in notification system and are expected to respond.

position required to activate and staff the OSC. All ERO personnel are expected to respond when notified by the emergency call-in notification system.

Table 8.4, Note 4 The on-shift Shift Manager, CRS, STA, and Chem Tech have the capability to do initial dose assessment and PAR. The TSC and EOF radiation assessment staff relieves them of this function.

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

VY will no longer be an operating nuclear power plant. The STA and on-shift Chemistry Technician positions will be eliminated.

Title changes for the CRS to CFH were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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

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After Reason for Change the CFH position throughout this Plan is considered to be equivalent to the CRS position. NCOs will perform duties typically associated with those performed by Auxiliary Operators and Control Room Operators, such as manipulation and monitoring of plant equipment.

Figure 8.1 Normal On-Shift Emergency Organization Replaced figure with Defueled On-Shift Emergency Organization figure.

Deleted the following positions:

Shift Technical Advisor Chem Tech Control Room Operators Replaced Control Room Supervisor with Certified Fuel Handler Replaced Auxiliary Operators with Non-Certified Operator VY will no longer be an operating nuclear power plant. The following on-shift positions will be 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)

CFH and three (3) NCOs.

Title changes for the CRS to CFH and AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY

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After Reason for Change Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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 Organization Replaced figure with VY Defueled Emergency The positions of EOF Manager and TSC Manager will not exist in the

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After Reason for Change Management Organization Deleted the following positions:

EOF Manager TSC Manager Permanently Defueled ERO.

Duties and responsibilities will be transferred to remaining positions within each Emergency Response Facility.

Figure 8.3 Technical Support Center Emergency Organization Replaced figure with Defueled Technical Support Center Emergency Organization Deleted the following positions:

TSC Manager TSC Communicator Mechanical Engineer Reactor Engineer Electrical /I&C Engineers IT Specialist The TSC positions identified for deletion will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the TSC.

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

Figure 8.5 Emergency Operations Facility Organization Replaced figure with Defueled Emergency Operations Facility Organization Deleted the following positions:

EOF Manager EOF Communicator Public Information Liaison EOF Log Keeper IT Specialist The EOF positions identified for deletion will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the EOF.

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After Reason for Change Figure 8.7 Joint Information Center Organization Replaced figure with Defueled Joint Information Center Organization Deleted the following positions:

Information Coordinator Technical Assistant Credentialing Press Release Writer Logistics Coordinator Inquiry Response Coordinator Media Monitoring JIC Log Keeper Inquiry Responders The JIC positions identified for deletion will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the JIC.

Section 9.2.1 - 2nd Paragraph

3. The Shift Technical Advisor reports to the Control Room and provides technical support as necessary; Deleted VY will no longer be an operating nuclear power plant. The STA position will be eliminated.

STA assignments in this functional area will be transferred to the CFH position. 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 9.2.2

5. The EOF Manager

5. The Emergency Director The EOF Manager position

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After Reason for Change establishes operations in the EOF/RC; establishes operations in the EOF/RC; will not exist in the Permanently Defueled ERO.

Duties and responsibilities will be transferred to remaining positions within the EOF.

Section 9.2.4 - 2nd Paragraph

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.

1. The Emergency Director may request that other personnel be mobilized in support of Vermont Yankee through activation of the Corporate Emergency Center.

The EOF Manager position will not exist in the Permanently Defueled ERO.

Duties and responsibilities will be transferred to remaining positions within the EOF.

Section 9.3 - 3rd Paragraph De-escalation from a Notification of Unusual Event to a recovery phase requires satisfying the following criteria:

1. Criticality controls are in effect;

2. The core is being adequately cooled;

3. The fission product release has been controlled;

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

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

6. Reactor coolant system pressure is under control; 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 fission product release has been controlled;

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

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

VY will no longer be an operating nuclear power plant and emplacement or retention of fuel into the reactor vessel will no longer be authorized. Therefore, the need for adequate core cooling, control over containment pressure and temperature and control of reactor coolant system pressure is not necessary.

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After Reason for Change 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 Center; Alert or Site Area Emergency or General Emergency Column Emergency Plant Manager TSC Manager Maintenance Coordinator (Electrical/Mechanical/I&C)

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

Operations Coordinator Engineering Support Group Emergency Plant Manager Maintenance Coordinator (Electrical/Mechanical/I&C)

Radiological Coordinator Engineering Coordinator(Project, System, Design)

Operations Coordinator The TSC positions identified for deletion will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the TSC.

Table 9.1, Operations Support Center; Alert or Site Area Emergency or General Emergency OSC Manager Radiation Protection Staff Chemistry Staff Spare Licensed Operators Spare Auxiliary Operators Control Instrument Specialists Plant Mechanics OSC Manager Radiation Protection Staff Chemistry Staff Spare AOs/CROs/NCOs Control Instrument Specialists Plant Mechanics VY will no longer be an operating nuclear power plant. Use of the term licensed is no longer appropriate.

The OSC positions identified for deletion will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the OSC.

Table 9.1, Emergency Emergency Director Emergency Director The EOF positions identified

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After Reason for Change Operations Facility/Recovery Center; Alert or Site Area Emergency or General Emergency Column Offsite Communicator Technical Advisor EOF Manager Administration and Logistics Coordinator Radiological Assessment Coordinator Personnel & Equipment Monitor

• Site/Offsite Monitoring Teams Public Information Liaison Offsite Communicator Technical Advisor Administration and Logistics Coordinator Radiological Assessment Coordinator

• Site/Offsite Monitoring Teams for deletion will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the EOF.

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

Section 10.1.1 10.1.1 Initial Offsite Radiological Dose Projection Capability Vermont Yankee has developed a method to quickly determine the projected offsite radiological conditions at various distances downwind of the plant site.

During the initial stages of an emergency, the Shift Manager or designated individual is responsible to perform the initial evaluation of offsite radiological conditions. The initial evaluation Deleted The Unified Rascal Interface (URI) will become the primary site specific dose assessment software for Vermont Yankee. This computer program replaces the existing ODPS and METPAC dose assessment software.

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After Reason for Change of offsite radiological conditions is accomplished by utilizing the Offsite Dose Projection System (ODPS).

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

Section 10.1.2 Once the EOF/RC is activated, Vermont Yankee utilizes a plume tracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiological accident conditions.

The system assumes a Gaussian, variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Station site. Both continuous and intermittent releases for either ground or stack release points can be evaluated. The effects of release height, building wake Vermont Yankee utilizes a plume tracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiological accident conditions. The system assumes a variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Station site. Both continuous and intermittent releases for either ground or stack release points can be evaluated. The effects of release height, building wake entrainment, The Unified Rascal Interface (URI) will become the primary site specific dose assessment software for Vermont Yankee. This computer program replaces the existing ODPS and METPAC dose assessment software. This section is revised to describe URI.

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After Reason for Change entrainment, momentum plume rise, precipitation and terrain height can be assessed in the evaluation. Plume trajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.

The model combines complex plume transport algorithms with the same dose assessment algorithms used by the model described in Section 10.1.1.

The model is programmed on a personal computer. The program is designed to graphically display the calculated plume characteristics on a 10-mile Vermont Yankee EPZ site map while providing transcripts of all dispersion and dose calculations.

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

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

after reactor shutdown; plant stack high range monitor response; plant stack flow rate at the time of the accident; and speed.

The assumptions incorporated in and the use of the nomograms contained in momentum plume rise, precipitation and terrain height can be assessed in the evaluation. Plume trajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.

The model combines complex plume transport algorithms with dose assessment algorithms. The model is programmed on a personal computer.

The program is designed to graphically display the calculated plume characteristics on a 10-mile Vermont Yankee EPZ site map while providing transcripts of all dispersion and dose calculations.

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After Reason for Change Figure 10.1 is discussed in Appendix C.

Section 10.2 - 1st Paragraph In the event a General Emergency has been declared, Vermont Yankee immediately recommends protective actions to state authorities based on plant conditions which include the status of core and containment conditions. At a minimum, the Shift Manager or Emergency Director, who is in charge of the emergency response activities, recommends that the general public be advised to seek shelter for the towns of Hinsdale, New Hampshire and Vernon, Vermont; and the towns located five miles downwind in the affected sectors.

In the event a General Emergency has been declared, Vermont Yankee immediately recommends protective actions to state authorities based on plant conditions. At a minimum, the Shift Manager or Emergency Director, who is in charge of the emergency response activities, recommends that the general public be advised to seek shelter for the towns of Hinsdale, New Hampshire and Vernon, Vermont; and the towns located five miles downwind in the affected sectors.

VY will no longer be an operating nuclear power plant and emplacement or retention of fuel into the reactor vessel will no longer be authorized. Therefore, the need to communicate the status of the core and containment conditions is not necessary.

Section 10.2 - 2nd Paragraph If plant conditions indicate a severe reactor accident exists involving actual or projected substantial core damage, Vermont Yankee recommends to the appropriate state officials evacuation of the towns of Hinsdale, New Hampshire and Vernon, Vermont; and all towns located five miles downwind in the affected sectors.

If plant conditions indicate a severe accident exists, 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.

VY will no longer be an operating nuclear power plant and emplacement or retention of fuel into the reactor vessel will no longer be authorized. Therefore, an accident involving the reactor the potential for actual or projected substantial core damage no longer exists.

Section 10.3 - 2nd Paragraph Table 10.2 specifies the guidelines on emergency dose limits for personnel providing Table 10.2 specifies the guidelines on emergency dose limits for personnel providing VY will no longer be an operating nuclear power plant. The on-shift

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

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 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.

Chemistry Technician positions will be eliminated.

Section 10.5.1 Medical Response Team members are trained in accordance with station procedures.

Medical response is provided by on-shift Fire Brigade members trained in basic first-aid and Cardiopulmonary resuscitation (CPR).

The Medical Response Team is being eliminated.

Medical response will be provided by Fire Brigade members available on site on a 24-hour per day basis.

Section 10.6 A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to safely shut down the reactor and perform the functions of the A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to maintain equipment important to the safe storage of spent fuel Revised to reflect important equipment during permanently shutdown and defueled plant condition.

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After Reason for Change emergency plan.

and perform the functions of the emergency plan.

Figure 10.1 Figure 10.1 Vermont Yankee Emergency Dose Rate Nomogram Deleted Figure VY will no longer be an operating nuclear power plant. Figure 10.1 is no longer applicable because it is based on the isotopic mix for a LOCA.

Section 11.3 - 4th Paragraph The Public Information Liaison and required staff report to the EOF/RC for coordinating the accident information between the plant and the Joint Information Center.

The Technical Advisor and required staff report to the EOF/RC for coordinating the accident information between the plant and the Joint Information Center.

The Technical Advisor will assume this duty in the permanently defueled condition.

Section 11.3 - 6th Paragraph Normally, a prerecorded message provides, on a daily basis, routine operating information, changes in plant operation, and other items of interest.

Normally, a prerecorded message provides, on a daily basis, routine plant information, changes in plant conditions, and other items of interest.

VY will no longer be an operating nuclear power plant.

Section 12.1.4 - Medical Drills To evaluate the training of the facility's medical response team and offsite medical response (ambulance and hospital), a medical drill is conducted annually with a simulated contaminated injured individual.

To evaluate the training of the facility's medical response and offsite medical response (ambulance and hospital), a medical drill is conducted annually with a simulated contaminated injured individual.

The Medical Response Team is being eliminated.

Medical response will be provided by Fire Brigade members available on site on a 24-hour per day basis.

Appendix B (A more detailed listing of emergency equipment is provided in OP 3506, "Emergency Equipment Readiness Check")

(A more detailed listing of emergency equipment is provided in OP-EQUIP-3506, "Emergency Equipment Readiness Check")

Editorial revision to procedure number.

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After Reason for Change Appendix C Appendix C Initial Offsite Dose Rate Estimation Appendix deleted in its entirety VY will no longer be an operating nuclear power plant. Appendix C is no longer applicable because it is based on the isotopic mix for a Loss of Coolant Accident (LOCA).

Appendix G - Section I OP-3507 OP-3508 OP-3510 OP-3513 OP-3547 OP-3548 AP-3712 EPOP-EREC-3507 EPOP-MED-3508 EPOP-OSMT-3510 EPOP-RAD-3513 EPOP-SEC-3547 EPOP-TERM-3548 EPAP-TRNG-3712 Editorial revision to procedure numbers.

Appendix G - Section I Not Applicable Add:

V-EN-FAP-EP-009, Use of KI for the Emergency Response Organization V-EN-FAP-EP-010, Severe Weather Response V-EN-FAP-EP-012, Severe Weather Recovery V-EN-EP-202, Equipment Important to Emergency Preparedness V-EN-EP-301, Emergency Planning Assessment of Offsite Emergency Response Capability See below.

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After Reason for Change Following a Natural Disaster V-EN-EP-305, Emergency Planning 10CFR50.54(q) Review Program V-EN-EP-306, Drills and Exercises V-EN-EP-307, Hostile Action Based Drills & Exercises V-EN-EP-308, Emergency Planning Critiques V-EN-EP-310, Emergency Response Organization Notification System V-EN-EP-401, Public Use of Emergency Preparedness Owner Controlled Area V-EN-EP-601, Corporate Emergency Center Operations V-EN-EP-801 - Emergency Response Organization Appendix G - Section I Not Applicable Add:

EPOP-AFA-10083 - Alternative Facility Activation EPOP-URI-10095 - Offsite Dose Assessment using the Unified Rascal Interface EPOP-AFA-10083 was developed and added to the Emergency Plan for compliance with 10 CFR Part 50, Appendix E Section IV.E.8.d.

EPOP-URI-10095 was developed and added to the Emergency Plan to address the change to URI.

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After Reason for Change Appendix G - Corporate Support Procedures Corporate Support Procedures Deleted EN-EP-311 will be deleted.

VY will no longer be an operating nuclear power plant.Section VI.1 of Appendix E to 10 CFR Part 50 indicates that ERDS is not applicable to nuclear power facilities that are shut down. Based on the permanently defueled status, this system is no longer necessary to transmit safety system parameter data to the NRC.

The applicable information from the remaining procedures will be relocated to a VY-specific procedure and added to the EPIP list (see above) and the Corporate Support Section of Appendix G will be deleted.

EN-EP-309 and EN-EP-606 will be deleted as neither procedure is applicable to VY. These procedures should not have been included in the VY Emergency Plan and removal is an editorial change.