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
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

• Entergy Entergy Nuclear Operations, Inc .

Vermont Yankee P.O. Box 0500 185 Old Ferry Road

• -w-. Brattleboro, VT 05302-0500 Tel 802 258 4183 Michael P. McKenney Emergency Planning Manager 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

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

BVY 15-003 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Emergency Plan Change, Revision 55

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

Title:

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

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? YES NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation is next part Alert and Notification System Design Report? NOT required.

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

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 EN-EP-305 REV 3

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

Title:

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

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

Enter Justification:

justification and complete Part VI.

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

EN-EP-305 REV 3

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

Title:

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

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]

EN-EP-305 REV 3

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

Title:

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

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) Preparer Signature Date:

Justine Anderson 2/4/15 (Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Reviewer Signature Date:

2/4/15 Tom Sowdon Nuclear EP Project Manager EN-EP-305 REV 3

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

Title:

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

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 EN-EP-305 REV 3

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

Title:

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

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 EN-EP-305 REV 3

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

Title:

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

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

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 1 OF 52 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 2 OF 52

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.

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 3 OF 52 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.

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 4 OF 52 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 REVIEW RESULTS OR SECTIONS YES NO (Regulations / Procedures) 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, No EPP at VY EN-LI-103)

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) UFSAR markups to reflect termination (10 CFR 50.71(e) / EN-LI-113, EN-LI-100, EN-LI-101) 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.

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 5 OF 52 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]

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 6 OF 52 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.

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 7 OF 52 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 No this form with the change package. (LBDCR LIC 14-14)

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

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

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 8 OF 52 1

VIII. SIGNATURES 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 Name (print) / Signature / Company / Department / Date Owner:

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

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.

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 9 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Table of Contents -- Updated page numbers and Editorial revision to reflect Section headings to reflect changes described below, changes described below, including updated page including updated page numbers numbers and deletion of and deletion of Section 6.2.5 Section 6.2.5 (Post Accident (Post Accident Sampling) and Sampling) and Section 7.10 Section 7.10 (Emergency (Emergency Response Data Response Data System). System).

Table of Contents - Appendix C Initial Offsite Dose (Deleted) VY will no longer be an Appendices Rate Estimate 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 Figure 8.1 Normal On-Shift Figure 8.1 Defueled On-Shift VY will no longer be an Figures Emergency Organization Emergency Organization operating nuclear power plant. The title change reflects the permanently defueled organizational structure.

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

Table of Contents - List of Figure 8.3 Technical Support Figure 8.3 Defueled VY will no longer be an Figures Center Emergency Organization Technical Support Center operating nuclear power Emergency Organization plant. The title change reflects the permanently defueled organizational EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 10 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change structure.

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

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

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

Table of Contents - List of Figure 10.1 Vermont Yankee (Deleted) VY will no longer be an Figures Emergency Dose Rate operating nuclear power Nomogram 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 - Events are in process or Alert - Events are in progress or Editorial revision to reflect Alert have occurred which involve an have occurred which involve an definition in NEI 99-01, Rev.

actual or potential substantial actual or potential substantial 5 degradation of the level of safety degradation of the level of safety of the plant or a security event of the plant or a security event that involves probable life that involves probable life threatening risk to site personnel threatening risk to site personnel EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 11 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change or damage to site equipment or damage to site equipment because of HOSTILE ACTION. because of HOSTILE ACTION.

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

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

Section 2.0 - Definition of General Emergency - Events General Emergency - Events Editorial revision to reflect General Emergency are in process or have occurred are in progress or have occurred definition in NEI 99-01, Rev.

which involve actual or imminent which involve actual or imminent 5 substantial core degradation or substantial core degradation or melting with potential for loss of melting with potential for loss of containment integrity or containment integrity or HOSTILE ACTION that results in HOSTILE ACTION that results in an actual loss of physical control an actual loss of physical control of the facility. Releases can be of the facility. Releases can be reasonably expected to exceed reasonably expected to exceed EPA Protective Action Guideline EPA Protective Action Guideline exposure levels offsite for more exposure levels offsite for more than the immediate site area. than the immediate site area.

Section 2.0 - Definition of Hostile Action - An act toward Hostile Action - An act toward Editorial revision to reflect Hostile Action an NPP or its personnel that an NPP or its personnel that definition in NEI 99-01, Rev.

includes the use of violent force includes the use of violent force 5 to destroy equipment, takes to destroy equipment, takes hostages, and/or intimidates the hostages, and/or intimidate the licensee to achieve an end. This licensee to achieve an end. This includes attack by air, land, or includes attack by air, land, or water using guns, explosives, water using guns, explosives, projectiles, vehicles, or other projectiles, vehicles, or other EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 12 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change devices used to deliver devices used to deliver destructive force. Other acts destructive force. Other acts that that satisfy the overall intent may satisfy the overall intent may be be included. HOSTILE ACTION included. HOSTILE ACTION should not be construed to should not be construed to include acts of civil disobedience include acts of civil disobedience or felonious acts that are not part or felonious acts that are not part of a concerted attack on the of a concerted attack on the NPP. Non-terrorism-based EALs NPP. Non-terrorism-based EALs should be used to address such should be used to address such activities, (e.g., violent acts activities, (e.g., violent acts between individuals in the owner between individuals in the owner controlled area). controlled area).

Section 2.0 - Definition of Notification of Unusual Event Notification of Unusual Event Editorial revision to reflect Notification of Unusual Event - Events are in process or have - Events are in progress or have definition in NEI 99-01, Rev.

occurred which indicate a occurred which indicate a 5 potential degradation of the level potential degradation of the level of safety of the plant or indicate of safety of the plant or indicate a a security threat to facility security threat to facility protection has been initiated. No protection has been initiated. No releases of radioactive material releases of radioactive material requiring offsite response or requiring offsite response or monitoring are expected unless monitoring are expected unless further degradation of safety further degradation of safety systems occurs. systems occurs.

Section 2.0 - Definition of Site Area Emergency - Events Site Area Emergency - Events Editorial revision to reflect Site Area Emergency are in process or have occurred are in progress or have occurred definition in NEI 99-01, Rev.

which involve an actual or likely which involve an actual or likely 5 major failures of plant functions major failures of plant functions needed for protection of the needed for protection of the public or HOSTILE ACTION that public or HOSTILE ACTION that results in intentional damage or results in intentional damage or malicious acts; (1) toward site malicious acts; (1) toward site personnel or equipment that personnel or equipment that EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 13 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change could lead to the likely failure of could lead to the likely failure of or; (2) that prevent effective or; (2) that prevent effective access to equipment needed for access to equipment needed for the protection of the public. Any the protection of the public. Any releases are not expected to releases are not expected to result in exposure levels which result in exposure levels which exceed EPA Protective Action exceed EPA Protective Action Guideline exposure levels Guideline exposure levels beyond the site boundary. beyond the site boundary.

Section 3.2 - 1st Paragraph, 5) Notify state authorities in 5) Notify state authorities in InForm added to the Item 5 Vermont, New Hampshire and Vermont, New Hampshire and Emergency Plan in Rev. 54.

Massachusetts using the Massachusetts using the InForm Emergency Notification System. Notification System.

Section 3.2 - 1st Paragraph, 7) Use the emergency 7) Use the notification plan to The Emergency Notification Item 7 notification system to notify notify appropriate personnel as System is a formal system appropriate personnel as set set forth in Figure 9.1 and Table used to notify the NRC forth in Figure 9.1 and Table 9.1. 9.1. 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 Vermont Yankee Nuclear Power VY will no longer be an Station is located on the west Station is located on the west operating nuclear power bank of the Connecticut River bank of the Connecticut River plant. The Site Description EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 14 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change immediately upstream of the immediately upstream of the has been revised to indicate Vernon Hydrostation, in the town Vernon Hydrostation, in the town the permanently shutdown of Vernon, Vermont. The of Vernon, Vermont. The and defueled condition.

Vermont Yankee Nuclear Power Vermont Yankee Nuclear Power Station is a boiling water reactor Station ceased power operations having a thermal rated power of and is permanently defueled in 1912 MWt. The station, shown accordance with 10 CFR in Figure 4.1, is located on about 50.82(a)(1)(i) and (ii). The 125 acres in Windham County, station, shown in Figure 4.1, is and is owned by Entergy, with located on about 125 acres in the exception of a narrow strip of Windham County, and is owned land between the Connecticut by Entergy, with the exception of River and the Vermont Yankee a narrow strip of land between property for which it has the Connecticut River and the perpetual rights and easements Vermont Yankee property for from the owner, New England which it has perpetual rights and Power Company. 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 15 OF 52 Emergency Plan Section Before (Rev. 54) 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 The nearest house is 1,300 feet Editorial. The Hinsdale from the Reactor Building and is from the Reactor Building and is Raceway no longer one of several west of the site. one of several west of the site. operates and reference is The Vernon Elementary School The Vernon Elementary School removed from the (approximate enrollment of 250 (approximate enrollment of 250 Emergency Plan.

pupils) is about 1,500 feet from pupils) is about 1,500 feet from the Reactor Building. The the Reactor Building. The nearest hospital, Brattleboro nearest hospital, Brattleboro Memorial, is approximately five Memorial, is approximately five (5) miles north-northwest from (5) miles north-northwest from the site. The nearest dairy farm the site. The nearest dairy farm is approximately 1/2-mile is approximately 1/2-mile northwest of the site. Additional northwest of the site. Additional dairy farms are located within a dairy farms are located within a 5-mile radius of the plant. The 5-mile radius of the plant. A largest sports facility in the nursing home is located 2 miles EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 16 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change vicinity is the Hinsdale Raceway, south of the plant. These areas located approximately three (3) have been noted since they have miles from the site. For racing required special planning events, the average attendance consideration by offsite is approximately 4,000. A authorities in the event of a nursing home is located 2 miles radiological emergency at south of the plant. These areas Vermont Yankee.

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 Notification of Unusual Event Editorial revision to reflect definition in NEI 99-01, Rev.

Events are in process or have Events are in progress or have 5

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

Section 5.1 - 2nd Paragraph Notification of Unusual Event Notification of Unusual Event VY will no longer be an conditions do not cause serious conditions do not cause serious operating nuclear power damage to the plant and may not damage to the plant. The plant. A change in require a change in operational purpose of the Notification of operational status is not a status. The purpose of the Unusual Event declaration is to: consideration due to the Notification of Unusual Event 1) ensure that the first step in permanently shutdown and declaration is to: 1) ensure that any response later found to be defueled plant condition.

the first step in any response necessary has been carried out; later found to be necessary has 2) bring the operating staff to a EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 17 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change been carried out; 2) bring the state of readiness; and 3) ensure operating staff to a state of that appropriate offsite readiness; and 3) ensure that notifications have been made in appropriate offsite notifications the event that additional support have been made in the event is required.

that additional support is required.

Section 5.2 - 1st Paragraph Alert Alert Editorial revision to reflect definition in NEI 99-01, Rev.

Events are in process or have Events are in progress or have 5

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

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

Section 5.3 - 1st Paragraph Site Area Emergency Site Area Emergency Editorial revision to reflect definition in NEI 99-01, Rev.

Events are in process or have Events are in progress or have 5

occurred which involve an actual occurred which involve an actual or likely major failures of plant or likely major failures of plant functions needed for protection functions needed for protection of the public or HOSTILE of the public or HOSTILE ACTION that results in ACTION that results in intentional damage or malicious intentional damage or malicious acts; (1) toward site personnel or acts; (1) toward site personnel or equipment that could lead to the equipment that could lead to the likely failure of or; (2) that likely failure of or; (2) that prevent effective access to prevent effective access to EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 18 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change equipment needed for the equipment needed for the protection of the public. Any protection of the public. Any releases are not expected to releases are not expected to result in exposure levels which result in exposure levels which exceed EPA Protective Action exceed EPA Protective Action Guideline exposure levels Guideline exposure levels beyond the site boundary. beyond the site boundary.

Section 5.4 - 1st Paragraph General Emergency General Emergency Editorial revision to reflect definition in NEI 99-01, Rev.

Events are in process or have Events are in progress or have 5

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

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

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

Figure 6.3 See After Column Deleted Radiation Protection Editorial revision to Offices accurately depict OSC Changed OSC layout.

Communication Center to OSC Manager and Briefing Room Deleted Chemistry Offices Changed Briefing Room to Rad Protection EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 19 OF 52 Emergency Plan Section Before (Rev. 54) 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 Editorial revision to Added NRC Room accurately depict EOF/RC Changed Chemistry & layout.

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 Section 7.3 The Utility Microwave and Radio The Utility Microwave and Radio VY will no longer be an Systems are located in the Systems are located in the operating nuclear power Control Room. The Utility Control Room. In the event that plant. There will no longer Microwave is a line-of-sight communications fail with the be a need to notify system dedicated system used to notify NRC due to loss of the load dispatchers of system load dispatchers of commercial telephone system, emergency conditions at the emergency conditions at the load dispatchers are advised that plant because the potential plant. The telephone has Vermont Yankee will use the to disrupt the power grid will EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 20 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change buttons marked for each load Utility Microwave System to no longer exist.

dispatcher. By pushing one of provide updates of plant the buttons on the telephone, it conditions to NRC Region I.

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.

Section 7.10 7.10 Emergency Response Data Deleted VY will no longer be an System operating nuclear power The Emergency Response Data plant.Section VI.1 of System (ERDS) is a direct Appendix E to 10 CFR Part real-time electronic transmission 50 indicates that ERDS is of the following types of not applicable to nuclear parameters to the NRC to assist power facilities that are shut them in monitoring the status of down. Based on the an emergency: permanently defueled status, this system is no Core and coolant system longer necessary to transmit data, safety system parameter data to the NRC.

Containment building EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 21 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change data, NRC Memorandum from the Director, Division of Radioactivity release Preparedness and data, and Response (NSIR) to Site meteorological data. Regions (Division of Reactor Projects) clarifies the Vermont Yankee maintains a requirements for continuous ERDS connection maintenance and use of with the NRC Operations Center.

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: InForm added to the Emergency Plan in Rev. 54.

State Police (VT, NH, MA) 1, 2 1, 2, 11 from CR 1, 2 1, 2, 11 State Police (VT, NH, MA) 1, 2, 9 1, 2, 9, 11 from EOF 1, 2, 9, 10 1, 2, 9, 10, 11 State EOCs (VT, NH, MA)

Add InForm to Table Key as #11 State EOCs (VT, NH, MA) from EOF Section 8.1 - 2nd Paragraph During normal operations, the The minimum staff on duty at the VY will no longer be an minimum staff on duty at the plant during all shifts consists of operating nuclear power EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 22 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change plant during all shifts consists of one (1) Shift Manager, one (1) plant. The following on-shift one (1) Shift Manager, one (1) Certified Fuel Handler (CFH), positions will be eliminated:

Control Room Supervisor, two three (3) Non-Certified Operators Shift Technical Advisor (2) Control Room Operators, six (NCO), one (1) Radiation (STA)

(6) Auxiliary Operators, one (1) Protection Technician and Shift Technical Advisor, one (1) security personnel as indicated Two (2) Control Room Radiation Protection Technician, in Figure 8.1. The responsibility Operators one (1) Chemistry Technician for determining the status of the Three (3) Auxiliary and security personnel as plant in an emergency is Operators indicated in Figure 8.1. The assigned to the Shift Manager or, Chemistry Technician responsibility for determining the in his absence from the Control Following permanent status of the plant in an Room, to the CFH who has the cessation of operations and emergency is assigned to the authority and responsibility to removal of fuel from the Shift Manager or, in his absence immediately initiate any reactor vessel, Operations from the Control Room, to the emergency actions, including on-shift personnel will Control Room Supervisor who emergency classification and consist of one (1) Shift has the authority and notification. Additional personnel Manager (SM), one (1) responsibility to immediately are available on an on-call basis Certified Fuel Handler initiate any emergency actions, to respond to plant emergencies. (CFH) and three (3) Non-including emergency Corrective action and repair, as Certified Operators (NCOs).

classification and notification. outlined in Table 8.4, is Title changes for the CRS to Additional personnel are performed by Operations staff CFH and the AO and CRO available on an on-call basis to on-shift until supplemented by to NCO were dependent respond to plant emergencies. additional ERO staff. upon NRC approval of Corrective action and repair, as proposed changes to the outlined in Table 8.4, is VY Technical Specifications performed by Operations staff (BVY 13-096) that replaced on-shift until supplemented by references to licensed and additional ERO staff. 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).

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 23 OF 52 Emergency Plan Section Before (Rev. 54) 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 Elements of the emergency Editorial change from response plan are activated response plan are activated onshift to on-shift subsequent to an emergency subsequent to an emergency declaration by the Shift Manager; declaration by the Shift Manager; designated company personnel designated company personnel are notified and will report to are notified and will report to designated locations. The designated locations. The emergency response action of emergency response action of the personnel already present the personnel already present are performed on a priority basis are performed on a priority basis depending on the emergency depending on the emergency conditions and the immediate conditions and the immediate need which those conditions need which those conditions dictate as determined by the dictate as determined by the on-onshift operations crew. The shift operations crew. The specific priorities facing the specific priorities facing the emergency response forces in emergency response forces in the various locations cannot be the various locations cannot be pre-established. They would be pre-established. They would be specific to the nature of the specific to the nature of the emergency and variable with emergency and variable with time as it proceeds. time as it proceeds.

Section 8.2 - 5th Paragraph In emergency situations, the In emergency situations, the VY will no longer be an Shift Manager, Emergency Plant Shift Manager, Emergency Plant operating nuclear power Manager, or OSC Manager can Manager, or OSC Manager can plant and emplacement or EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 24 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change authorize actions, without authorize actions, without retention of fuel into the following the complete work following the complete work reactor vessel will no longer order process, if these actions order process, if these actions be authorized. Therefore a prevent the following: prevent the following: plant trip will no longer be applicable.

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

Plant trip.

Section 8.2.2 - 1st 5. Develop guidance for plant 5. Develop guidance for plant VY will no longer be an Paragraph, Item 5 shift operations concerning plant shift operations concerning plant operating nuclear power protection of the reactor core; protection; 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 A qualified manager assumes A qualified manager assumes VY will no longer be an Paragraph the role of Emergency Plant the role of Emergency Plant operating nuclear power Manager under all emergency Manager under all emergency plant and emplacement or conditions. To assist the conditions. To assist the retention of fuel into the Emergency Plant Manager, the Emergency Plant Manager, the reactor vessel will no longer TSC is staffed by TSC is staffed by representatives be authorized. Therefore, representatives from the from the following departments the need to maintain a following departments as as depicted in Figure 8.3: Reactor Engineer in the depicted in Figure 8.3: TSC is no longer applicable.

Operations Operations Maintenance Maintenance EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 25 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Reactor Engineering Engineering Engineering Chemistry Chemistry (in the OSC) Radiation Protection Radiation Protection Security (stationed at the off site command post)

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 During implementation of Severe EPOP-TSC-3542 states that Accident Management (SAM), Accident Management (SAM), the Operations Coordinator the senior licensed individual in the Operations Coordinator in in the TSC assumes the the TSC will assume the role of the TSC will assume the role of duty of SAM Decision Decision Maker as defined in the Decision Maker as defined in Maker.

SAM Guideline. plant procedures.

Table 8.3, Page 2 of 3 Each State Health representative Each State Health representative The EOF Manager position at the EOF/RC will request at the EOF/RC will request will not exist in the monitoring updates from the monitoring updates from the Permanently Defueled ERO.

EOF Manager. Lead Offsite Liaison. 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 Technical Advisor at the The position of Public the EOF/RC relays accident EOF/RC relays accident status Information Liaison will not status reports to the Joint reports to the Joint Information exist in the Permanently Information Center. Center. Defueled Emergency Response Organization EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 26 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change (ERO). Duties and responsibilities will be transferred to the Technical Advisor position.

Table 8.4 - Page 1 of 2, VY will no longer be an Functional Area - Plant operating nuclear power Operations & Assessment of plant. The following on-shift Operational Aspects 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 27 OF 52 Emergency Plan Section Before (Rev. 54) 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; VY will no longer be an Functional Area - operating nuclear power Notification/Communication; plant. The STA position will Major Tasks - Notify be eliminated.

Licensee, State, local and Following permanent federal personnel & maintain cessation of operations, the communication Chemistry Technician Position will not be EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 28 OF 52 Emergency Plan Section Before (Rev. 54) 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; VY will no longer be an Functional Area - operating nuclear power Radiological Accident plant. The STA and on-shift Assessment and Support of Chemistry Tech positions Operational Accident EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 29 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Assessment; Major Tasks - will be eliminated.

Offsite Dose Assessment 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; This change does not Functional Area - represent a change to the Radiological Accident number of on-shift RP EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 30 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Assessment and Support of Technicians. The number of Operational Accident on-shift RP Technicians Assessment; Major Tasks - remains one (1). The Onsite (out of plant) 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; VY will no longer be an Functional Area - operating nuclear power Radiological Accident plant. The on-shift Assessment and Support of Chemistry Tech position will Operational Accident be eliminated.

Assessment; Major Tasks -

Removal of the on-shift Chemistry/Radiochemistry Chemistry Tech position has been evaluated in the VY analysis of proposed post-shutdown on-shift EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 31 OF 52 Emergency Plan Section Before (Rev. 54) 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; VY will no longer be an Functional Area - Plant operating nuclear power System Engineering; Major plant. The STA position will Tasks - Shift Technical be eliminated.

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

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

Table 8.4 - Page 1 of 2; The Defueled Organization Functional Area - Repair & contains three (3) NCOs on-Corrective Actions; Major shift. This on-shift Tasks - Mechanical complement has been Maintenance evaluated in the VY analysis of proposed post-shutdown EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 32 OF 52 Emergency Plan Section Before (Rev. 54) 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; The CRO position is Functional Area - Repair & eliminated in the post-Corrective Actions; Major shutdown condition. The Tasks - Rad Waste Defueled Organization Operator 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 33 OF 52 Emergency Plan Section Before (Rev. 54) 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; The Defueled Organization Functional Area - Repair & consists of three (3) NCOs Corrective Actions; Major on-shift. This on-shift Tasks - Electrical complement has been Maintenance/Instrumentation evaluated in the VY analysis

& Control Technician 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 34 OF 52 Emergency Plan Section Before (Rev. 54) 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; The Defueled Organization Functional Area - Protective consists of three (3) NCOs Actions (In Plant); Major on-shift. This on-shift Tasks - Radiation complement has been Protection, access control, evaluated in the VY analysis HP, coverage for repair, of proposed post-shutdown corrective actions, search & on-shift staffing in rescue, first aid & firefighting, conjunction with the personnel monitoring, postulated accidents that dosimetry 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).

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 35 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4, Note **** May be performed by Deleted VY will no longer be an engineering aide to Shift operating nuclear power Manager (STA for ENVY) 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 AP 0894 specifies minimum shift The Defueled on-shift staffing requirements. FB staffing requirements. FB staffing has been evaluated requires 5 persons per TRM and requires 5 persons per TRM and in the VY analysis of the Vermont Yankee Nuclear the Vermont Yankee Nuclear proposed post-shutdown on-Power Station On-Shift Staffing Power Station Analysis of shift staffing in conjunction Analysis. The staffing analysis is Proposed Post-Shutdown with the postulated maintained as a controlled On-Shift Staffing. The staffing accidents that will be document and is effective 30 analysis was evaluated to reflect applicable in the days after OSRC approval. STA VYs permanently shutdown and permanently defueled and Chemistry Tech must be defueled conditions, including condition.

available within 10 minutes to the on-shift staff composition and the Control Room. VY letter to revised accident analyses.

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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 36 OF 52 Emergency Plan Section Before (Rev. 54) 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 All NCOs use digital dosimeters Title changes for the AOs with features for dose rate and with features for dose rate and and CROs to NCO were total dose monitoring. AOs are total dose monitoring. NCOs are dependent upon NRC trained to self-monitor in an trained to self-monitor in an approval of proposed emergency. emergency. 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 ENVY has designated ERO The Defueled Organization holders who staff positions members who staff positions will consist of fewer than 4 required to meet minimum required to meet minimum teams rotating ERO duty.

staffing to activate TSC, OSC staffing to activate the TSC, OSC Additional changes to this and EOF (see E Plan Figures and EOF. The minimum staff note are editorial to remove 8.3 through 8.5). There are a positions required to activate the references to pagers and minimum of 4 persons per TSC and EOF are shown in E pager holders.

position (4 teams who rotate Plan Figures 8.3 and 8.5. The duty). However, all persons on OSC Manager is the only EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 37 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change teams are expected to respond. position required to activate and In addition, all other ERO staff the OSC. All ERO personnel not on pagers are personnel are expected to notified by the emergency call-in respond when notified by the notification system and are emergency call-in notification expected to respond. system.

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

assessment staff relieves them relieves them of this function.

Title changes for the CRS to of this function.

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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 38 OF 52 Emergency Plan Section Before (Rev. 54) 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 Replaced figure with Defueled VY will no longer be an Organization On-Shift Emergency operating nuclear power Organization figure. plant. The following on-shift positions will be eliminated:

Deleted the following positions:

STA Shift Technical Advisor Two (2) Control Room Chem Tech Operators Control Room Operators Three (3) Auxiliary Replaced Control Room Operators Supervisor with Certified Fuel Chemistry Technician Handler Following permanent Replaced Auxiliary Operators cessation of operations and with Non-Certified Operator 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 39 OF 52 Emergency Plan Section Before (Rev. 54) 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 Replaced figure with VY The positions of EOF Organization Defueled Emergency Manager and TSC Manager will not exist in the EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 40 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Management Organization Permanently Defueled ERO.

Duties and responsibilities Deleted the following positions:

will be transferred to EOF Manager remaining positions within TSC Manager each Emergency Response Facility.

Figure 8.3 Technical Support Center Replaced figure with Defueled The TSC positions identified Emergency Organization Technical Support Center for deletion will not exist in Emergency Organization the Permanently Defueled ERO. Duties and Deleted the following positions:

responsibilities will be TSC Manager transferred to remaining TSC Communicator positions within the TSC.

Mechanical Engineer Reactor Engineer Electrical /I&C Engineers IT Specialist Figure 8.4 Operations Support Center Deleted figure ERO Staffing changes result Emergency Organization in one remaining OSC position (OSC Manager) - A figure is no longer necessary to describe the OSC organization.

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

responsibilities will be EOF Manager transferred to remaining EOF Communicator positions within the EOF.

Public Information Liaison EOF Log Keeper IT Specialist EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 41 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Figure 8.7 Joint Information Center Replaced figure with Defueled The JIC positions identified Organization Joint Information Center for deletion will not exist in Organization the Permanently Defueled ERO. Duties and Deleted the following positions:

responsibilities will be Information Coordinator transferred to remaining Technical Assistant positions within the JIC.

Credentialing Press Release Writer Logistics Coordinator Inquiry Response Coordinator Media Monitoring JIC Log Keeper Inquiry Responders Section 9.2.1 - 2nd 3. The Shift Technical Advisor Deleted VY will no longer be an Paragraph reports to the Control Room operating nuclear power and provides technical plant. The STA position will support as necessary; 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 42 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change establishes operations in the establishes operations in the will not exist in the EOF/RC; EOF/RC; Permanently Defueled ERO.

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

Section 9.2.4 - 2nd 1. The Emergency Director may 1. The Emergency Director may The EOF Manager position Paragraph request that the EOF request that other personnel will not exist in the Manager mobilize other be mobilized in support of Permanently Defueled ERO.

personnel in support of Vermont Yankee through Duties and responsibilities Vermont Yankee through activation of the Corporate will be transferred to activation of the Corporate Emergency Center. remaining positions within Emergency Center. the EOF.

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

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

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

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

4. Control has been established over containment pressure 4. Notification of Unusual Event and temperature; conditions have been reviewed, are under control,

5. An adequate heat transfer and are not expected to path to an ultimate heat sink deteriorate further.

has been established;

6. Reactor coolant system pressure is under control; EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 43 OF 52 Emergency Plan Section Before (Rev. 54) 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 Emergency Plant Manager Emergency Plant Manager The TSC positions identified Center; Alert or Site Area for deletion will not exist in TSC Manager Maintenance Coordinator Emergency or General the Permanently Defueled (Electrical/Mechanical/I&C)

Emergency Column Maintenance Coordinator ERO. Duties and (Electrical/Mechanical/I&C) Radiological Coordinator responsibilities will be transferred to remaining Radiological Coordinator Engineering Coordinator(Project, System, Design) positions within the TSC.

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

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

Spare Auxiliary Operators Control Instrument Specialists The OSC positions identified for deletion will not exist in Control Instrument Specialists Plant Mechanics the Permanently Defueled Plant Mechanics 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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 44 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Operations Facility/Recovery Offsite Communicator Offsite Communicator for deletion will not exist in Center; Alert or Site Area the Permanently Defueled Technical Advisor Technical Advisor Emergency or General ERO. Duties and Emergency Column EOF Manager Administration and Logistics responsibilities will be Coordinator transferred to remaining Administration and Logistics Coordinator Radiological Assessment positions within the EOF.

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

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

Section 10.1.1 10.1.1 Initial Offsite Radiological Dose Deleted The Unified Rascal Interface Projection Capability (URI) will become the Vermont Yankee has developed primary site specific dose a method to quickly determine assessment software for the projected offsite radiological Vermont Yankee. This conditions at various distances computer program replaces downwind of the plant site. the existing ODPS and During the initial stages of an METPAC dose assessment emergency, the Shift Manager or software.

designated individual is responsible to perform the initial evaluation of offsite radiological conditions. The initial evaluation EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 45 OF 52 Emergency Plan Section Before (Rev. 54) 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 Vermont Yankee utilizes a plume The Unified Rascal Interface Yankee utilizes a plume tracking/dose tracking/dose projection system, which (URI) will become the projection system, which is capable of is capable of providing near real time primary site specific dose providing near real time offsite dose offsite dose estimated for actual assessment software for estimated for actual meteorological meteorological and radiological Vermont Yankee. This and radiological accident conditions. accident conditions. The system computer program replaces The system assumes a Gaussian, assumes a variable trajectory, plume the existing ODPS and variable trajectory, plume segment segment transport model designed to METPAC dose assessment transport model designed to handle the handle the site-specific atmospheric software. This section is site-specific atmospheric dispersion dispersion characteristics associated revised to describe URI.

characteristics associated with the with the Vermont Yankee Nuclear Vermont Yankee Nuclear Power Station Power Station site. Both continuous site. Both continuous and intermittent and intermittent releases for either releases for either ground or stack ground or stack release points can be release points can be evaluated. The evaluated. The effects of release effects of release height, building wake height, building wake entrainment, EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 46 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change entrainment, momentum plume rise, momentum plume rise, precipitation precipitation and terrain height can be and terrain height can be assessed in assessed in the evaluation. Plume the evaluation. Plume trajectories are trajectories are based on onsite based on onsite meteorological tower meteorological tower information and information and topography of the topography of the Connecticut River Connecticut River Valley.

Valley.

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

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

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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 47 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Figure 10.1 is discussed in Appendix C.

st Section 10.2 - 1 Paragraph In the event a General In the event a General VY will no longer be an Emergency has been declared, Emergency has been declared, operating nuclear power Vermont Yankee immediately Vermont Yankee immediately plant and emplacement or recommends protective actions recommends protective actions retention of fuel into the to state authorities based on to state authorities based on reactor vessel will no longer plant conditions which include plant conditions. At a minimum, be authorized. Therefore, the status of core and the Shift Manager or Emergency the need to communicate containment conditions. At a Director, who is in charge of the the status of the core and minimum, the Shift Manager or emergency response activities, containment conditions is Emergency Director, who is in recommends that the general not necessary.

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

Vermont; and the towns located five miles downwind in the affected sectors.

Section 10.2 - 2nd Paragraph If plant conditions indicate a If plant conditions indicate a VY will no longer be an severe reactor accident exists severe accident exists, Vermont operating nuclear power involving actual or projected Yankee recommends to the plant and emplacement or substantial core damage, appropriate state officials retention of fuel into the Vermont Yankee recommends to evacuation of the towns of reactor vessel will no longer the appropriate state officials Hinsdale, New Hampshire and be authorized. Therefore, an evacuation of the towns of Vernon, Vermont; and all towns accident involving the Hinsdale, New Hampshire and located five miles downwind in reactor the potential for Vernon, Vermont; and all towns the affected sectors. actual or projected located five miles downwind in substantial core damage no the affected sectors. longer exists.

Section 10.3 - 2nd Paragraph Table 10.2 specifies the Table 10.2 specifies the VY will no longer be an guidelines on emergency dose guidelines on emergency dose operating nuclear power limits for personnel providing limits for personnel providing plant. The on-shift EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 48 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change emergency response duties emergency response duties Chemistry Technician which is consistent with the which is consistent with the positions will be eliminated.

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

exposures ALARA.

Section 10.5.1 Medical Response Team Medical response is provided by The Medical Response members are trained in on-shift Fire Brigade members Team is being eliminated.

accordance with station trained in basic first-aid and Medical response will be procedures. Cardiopulmonary resuscitation provided by Fire Brigade (CPR). members available on site on a 24-hour per day basis.

Section 10.6 A range of protective actions to A range of protective actions to Revised to reflect important protect onsite personnel during protect onsite personnel during equipment during hostile action is provided to hostile action is provided to permanently shutdown and ensure the continued ability to ensure the continued ability to defueled plant condition.

safely shut down the reactor and maintain equipment important to perform the functions of the the safe storage of spent fuel EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 49 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change emergency plan. and perform the functions of the emergency plan.

Figure 10.1 Figure 10.1 Vermont Yankee Deleted Figure VY will no longer be an Emergency Dose Rate operating nuclear power Nomogram 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 The Technical Advisor and The Technical Advisor will and required staff report to the required staff report to the assume this duty in the EOF/RC for coordinating the EOF/RC for coordinating the permanently defueled accident information between the accident information between the condition.

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

Section 11.3 - 6th Paragraph Normally, a prerecorded Normally, a prerecorded VY will no longer be an message provides, on a daily message provides, on a daily operating nuclear power basis, routine operating basis, routine plant information, plant.

information, changes in plant changes in plant conditions, and operation, and other items of other items of interest.

interest.

Section 12.1.4 - Medical To evaluate the training of the To evaluate the training of the The Medical Response Drills facility's medical response team facility's medical response and Team is being eliminated.

and offsite medical response offsite medical response Medical response will be (ambulance and hospital), a (ambulance and hospital), a provided by Fire Brigade medical drill is conducted medical drill is conducted members available on site annually with a simulated annually with a simulated on a 24-hour per day basis.

contaminated injured individual. contaminated injured individual.

Appendix B (A more detailed listing of (A more detailed listing of Editorial revision to emergency equipment is emergency equipment is procedure number.

provided in OP 3506, provided in OP-EQUIP-3506, "Emergency Equipment "Emergency Equipment Readiness Check") Readiness Check")

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 50 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Appendix C Appendix C Initial Offsite Dose Appendix deleted in its entirety VY will no longer be an Rate Estimation 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 EPOP-EREC-3507 Editorial revision to procedure numbers.

OP-3508 EPOP-MED-3508 OP-3510 EPOP-OSMT-3510 OP-3513 EPOP-RAD-3513 OP-3547 EPOP-SEC-3547 OP-3548 EPOP-TERM-3548 AP-3712 EPAP-TRNG-3712 Appendix G - Section I Not Applicable Add: See below.

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 EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 51 OF 52 Emergency Plan Section Before (Rev. 54) 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 was developed and added to the EPOP-AFA-10083 - Alternative Emergency Plan for Facility Activation compliance with 10 CFR EPOP-URI-10095 - Offsite Dose Part 50, Appendix E Section Assessment using the Unified IV.E.8.d.

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

EN-LI-100 REV. 16

ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORM PAGE 52 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Appendix G - Corporate Corporate Support Procedures Deleted EN-EP-311 will be deleted.

Support Procedures 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.

EN-LI-100 REV. 16