ML14168A302

Permanently Defueled Emergency Plan and Emergency Action Level Scheme

ML14168A302
Person / Time
Site:	Vermont Yankee
Issue date:	06/12/2014
From:	Wamser C J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-033, TAC MF3668
Download: ML14168A302 (194)

Text

SEntergy Entergy Nuclear Operations, Inc.Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President 10 CFR 50.90 10 CFR 50.54(qX4)

BVY 14-033 June 12, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Vermont Yankee Permanently Defueled Emergency Plan and Emergency Action Level Scheme Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML1 3273A204)2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the Vermont Yankee Emergency Plan," BVY 14-018, dated March 24, 2014 (ADAMS Accession No. ML14085A257) (TAC No. MF3668)3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," BVY 14-009, dated March 14, 2014 (ADAMS Accession No. ML1 4080A1 41) (TAC No. MF3614)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) requests an amendment to Renewed Facility Operating License Number DPR-28 for Vermont Yankee Nuclear Power Station (VY). The proposed amendment would revise the site emergency plan (SEP) and Emergency Action Level (EAL) scheme for the permanently defueled condition.

The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2.In Reference 1, ENO provided notification that it intended to permanently cease power operation of VY at the end of the current operating cycle. In Reference 2, ENO submitted proposed changes to the VY SEP to reduce the minimum required on-shift and Emergency Response Organization (ERO) staffing following the transition from an operating facility to a permanently defueled facility.

BVY 14-033 / Page 2 of 3 The proposed changes would result in a Permanently Defueled Emergency Plan (PDEP) and a Permanently Defueled EAL scheme, consistent with Nuclear Energy Institute (NEI) 99-01,"Development of Emergency Action Levels for Non-Passive Reactors," Revision 6.The proposed PDEP and Permanently Defueled EAL scheme are predicated on approval of requests for exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR Part 50, Appendix E, Section IV, previously submitted in Reference

3. The proposed PDEP reduces the scope of offsite and onsite emergency planning commensurate with the permanently defueled condition.

Additionally, the proposed PDEP states that notification of an emergency declaration will be made to State authorities within 60 minutes of an emergency declaration or change in classification.

Reference 3 included an analysis which shows that 15.4 months following shutdown of the VY reactor, the spent fuel stored in the spent fuel pool will have decayed to the point where the requested exemptions, PDEP and Permanently Defueled EAL scheme may be implemented without additional compensatory actions. Following the final VY shutdown, which is expected to occur by the end of 2014 (Reference 1), 15.4 months after shutdown will occur near the middle of April 2016.The proposed PDEP and Permanently Defueled EAL scheme are commensurate with the significantly reduced spectrum of credible accidents that can occur in the permanently defueled condition and are necessary to properly reflect the conditions of the facility while continuing to preserve the VY Decommissioning Trust Fund and the effectiveness of the emergency plan.The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and ENO has determined that this change involves no significant hazards consideration.

ENO has also determined that the proposed emergency plan changes satisfy the criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9) and do not require an environmental review. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required.Attachment 1 to this letter provides a description, technical analysis, significant hazards determination, and environmental considerations evaluation for the proposed amendment.

Attachment 2 provides the proposed PDEP. Attachment 3 provides the Permanently Defueled EAL Bases Document.

Attachment 4 provides the proposed Permanently Defueled EAL scheme.Attachment 5 provides a comparison of the proposed Permanently Defueled EAL Bases Document to the corresponding information contained in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6.This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91 (b)(1), a copy of this application, with attachments, is being provided to the designated state of Vermont official.ENO requests review and approval of the proposed license amendment by December 1, 2015 with an effective date of April 15, 2016 and a 90 day implementation period. Approval of these changes by December 1, 2015 will allow VY adequate time to implement the changes to the emergency plan and EAL Scheme by the requested effective date.If you have any questions on this transmittal, please contact Mr. Coley Chappell at 802-451-3374.

BVY 14-033 / Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 12, 2014.Sincerely, CJW/plc Attachments:

1.2.3.4.5.Description and Evaluation of Proposed Changes Permanently Defueled Emergency Plan Permanently Defueled Emergency Action Level Bases Document Permanently Defueled Emergency Action Level Scheme Comparison Matrix for Permanently Defueled EALs Based on NEI 99-01,"Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 cc: Mr. William M. Dean Region 1 Administrator U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601 BVY 14-033 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Description and Evaluation of Proposed Changes BVY 14-033 / Attachment 1 / page 1 of 14 1.

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Renewed Facility Operating License (OL) DPR-28 for Vermont Yankee Nuclear Power Station (VY).The proposed changes would revise the VY site emergency plan (SEP) and Emergency Action Level (EAL) scheme to support the pending permanent cessation of operations and permanent defueling of the VY reactor at the end of the current operating cycle (Reference 1). This request contains the proposed VY Permanently Defueled Emergency Plan (PDEP) and the Permanently Defueled Emergency Action Level (EAL) scheme for NRC review and approval.The proposed PDEP and Permanently Defueled EAL scheme are predicated on approval of requests for exemptions from portions of 10 CFR 50.47(b);

10 CFR 50.47(c)(2);

and 10 CFR Part 50, Appendix E, Section IV, previously submitted by letter dated March 14, 2014 (Reference 2).Reference 2 contained an analysis which shows that, within 15.4 months after shutdown, the spent fuel stored in the spent fuel pool (SFP) will have decayed to the extent that the requested exemptions, PDEP and Permanently Defueled EAL scheme may be implemented at VY without any additional compensatory actions. Following the VY shutdown, which is expected by the end of 2014 (Reference 1), 15.4 months after shutdown will occur near the middle of April 2016.Based on approval of the previously submitted requests for exemption (Reference 2), the proposed PDEP meets the applicable standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E for a permanently defueled reactor.2. PROPOSED CHANGES The proposed amendment would modify the VY license by revising the SEP and the associated EAL scheme to reflect the pending permanent cessation of operation and permanent defueling of the VY reactor at the end of the current operating cycle and anticipated conditions following 15.4 months of decay of the spent fuel in the SFP. In a permanently defueled condition, the number and severity of potential radiological accidents is significantly less than when the plant is operating.

Therefore, the offsite radiological consequences of accidents possible at VY are substantially lower. The analyses of the potential radiological impact of accidents while the plant is in a permanently defueled condition indicate that no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary.

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 2). Therefore, the proposed PDEP states that notification of an emergency declaration will be made to State authorities within 60 minutes of an emergency declaration or change in classification.

The proposed PDEP reduces the scope of offsite and onsite emergency planning commensurate with the spectrum of credible accidents that can occur in a permanently defueled condition.

The proposed PDEP meets the applicable standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E, considering the previously submitted requests for exemption (Reference 2).The current EAL scheme is based upon NEI 99-01, "Methodology for Development of Emergency Action Levels," Revision 5, approved February 22, 2008 (Reference 3). ENO determined that a revision to the EAL scheme to implement the EAL scheme contained in Appendix C of NEI 99-01, Rev. 6 (Reference 4), Recognition Category PD (Permanently Defueled), is appropriate for the permanently defueled conditions, as a result of the supporting analyses presented in Reference

2.

BVY 14-033 / Attachment 1 /page 2 of 14 The NEI 99-01, Rev. 6 guidance has been endorsed by the NRC in a letter dated March 28, 2013 (Reference 5).3. REASON FOR PROPOSED CHANGES The proposed changes are desired to reflect the pending permanent cessation of operation and permanent defueling of the VY reactor at the end of the current operating cycle and anticipated conditions following 15.4 months of decay of the spent fuel in the SFP. After the reactor is shut down, all fuel assemblies will be removed from the reactor vessel and placed in the SFP. Upon docketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i))

and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and in the Independent Spent Fuel Storage Installation (ISFSI) until it is shipped off-site in accordance with the schedules that will be described in the Post-Shutdown Decommissioning Activities Report (PSDAR) and updated Irradiated Fuel Management Plan.The proposed revisions to the SEP and EAL scheme are commensurate with the reduction in radiological hazards associated with the permanently defueled condition and will allow the facility to transition to an emergency plan and EAL scheme required for a permanently defueled facility.

The proposed changes are necessary to properly reflect the conditions of the facility 15.4 months following shutdown while continuing to preserve the VY Decommissioning Trust Fund and the effectiveness of the emergency plan.4. BACKGROUND VY is located in the town of Vernon, Vermont in Windham County on the west shore of the Connecticut River immediately upstream of the Vernon Hydrostation.

VY is a boiling water reactor with a rated thermal power of 1912 MWt. The station is located on approximately 125 acres in Windham County, and is owned by Entergy Nuclear Vermont Yankee, LLC, with the exception of a narrow strip of land between the Connecticut River and the VY property for which Entergy Nuclear Vermont Yankee, LLC has perpetual rights and easements from the owner.The site is bounded by the Connecticut River (Vernon Pond) on the east, by farm and pasture land mixed with wooded areas on the north and south, and by the town of Vernon on the west. Warwick and Northfield State Forests (approximately 8 miles southwest of the site), Green Mountain National Forest (approximately 18 miles southwest of the site) and the Pisgah Mountain Range (northeast of the site) limit the population density and land use within a 50-mile radius of the site.Most of the land around the site is undeveloped.

The developed land is used for agricultural, dairying, and for residential areas within small villages.

The primary agricultural crop is silage corn, which is stored for year-round feed for milk cows.Section 14 of the VY Updated Final Safety Analysis Report (UFSAR) describes the design basis accident (DBA) scenarios that are applicable to VY during power operations and describes the accidents with the greatest potential for radiation exposure of any accident considered under the same assumptions.

The most severe postulated accidents for nuclear power plants involve damage to the nuclear reactor core and the release of fission products.

The UFSAR accident scenarios include a Control Rod Drop Accident (CRDA), a Loss-of-Coolant Accident (LOCA), a Refueling/Fuel Handling Accident (RA/FHA) and a Main Steam Line Break Accident.Following docketing of its certification of permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(ii), and within two years following cessation of operations, VY will submit a Post-Shutdown Decommissioning Activities Report (PSDAR), which will identify the BVY 14-033 / Attachment 1 / page 3 of 14 selected method of decommissioning for VY. At the end of the current operating cycle, the VY reactor will be permanently shut down. After the reactor is shut down, all fuel assemblies will be removed from the reactor vessel and placed in the SFP. The irradiated fuel will be stored in the SFP and the ISFSI until it is shipped off-site in accordance with the schedules described in the PSDAR and updated Irradiated Fuel Management Plan.When the reactor is permanently defueled, the SFP and its supporting systems will be modified and dedicated to spent fuel storage. With the reactor defueled, the reactor vessel assembly and supporting structures and systems are no longer in operation and have no function related to the safe storage and management of irradiated fuel in the SFP. A SFP cooling system is provided to remove decay heat from spent fuel stored in the SFP and to maintain a specified water temperature and level.5. TECHNICAL EVALUATION

5.1 Accident

Analysis Overview Following the cessation of reactor operations at VY and the permanent removal of the fuel from the reactor vessel, the postulated accidents involving failure or malfunction of the reactor and supporting structures, systems and components will no longer be applicable.

A summary of the postulated radiological accidents analyzed for the permanently shutdown and defueled condition of VY is presented below. According to the EPA, "Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment," dated March 2013 (EPA PAG Manual), Section 2.3.5, "PAGs and Nuclear Facilities Emergency Planning Zones (EPZ)," EPZs are not necessary at those facilities where it is not possible for PAGs to be exceeded off-site (Reference 6).5.1.1 Consequences of Design Basis Events The postulated DBA that will remain applicable to VY in its permanently shutdown and defueled condition is the FHA in the reactor building where the SFP is located. An analysis, based on the FHA, was performed to determine the dose to operators in the Control Room and the public at the Exclusion Area Boundary (EAB or "Site Boundary")

and Low Population Zone (LPZ), as a function of time after shutdown.

The analysis shows that the dose at the EAB and LPZ 17 days after shutdown (with no credit for containment) is less than 1 rem Total Effective Dose Equivalent (TEDE), which is below the EPA PAG threshold of 1 rem for recommended evacuation.

Due to the amount of decay calculated (17 days), the results of this analysis may be applied after January 17, 2015, assuming a VY shutdown by the end of December 2014. The analysis was submitted for NRC review in Reference

7.

BVY 14-033 / Attachment 1 / page 4 of 14 5.1.2 Consequences of Beyond Design Basis Events 5.1.2.1 Hottest Fuel Assembly Adiabatic Heatup -Beyond Design Basis Event The analysis provided in Reference 2 compares the conditions for the hottest fuel assembly stored in the VY SFP to a criterion proposed in SECY-99-168 (Reference

8) applicable to offsite emergency response for the unit in the decommissioning process. This criterion considers the time for the hottest assembly to heat up from 30 degrees Celsius (0C) to 9000C adiabatically.

If the heat up time is greater than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, then offsite emergency preplanning involving the plant is not necessary.

Based on the limiting fuel assembly for decay heat and adiabatic heatup analysis, at 15.4 months after shutdown (15.4 months decay time), the time for the hottest fuel assembly to reach 9000C is 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the assemblies have been uncovered.

As stated in NUREG-1738, 'Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants" (February 2001) (Reference 9), 9000C is an acceptable temperature to use for assessing onset of fission product release under transient conditions (to establish the critical decay time for determining availability of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to evacuate) if fuel and cladding oxidation occurs in air.Because of the length of time it would take for the adiabatic heatup to occur, there is ample time to respond to any partial drain down event that might cause such an occurrence by restoring SFP cooling or makeup. As a result, the likelihood that such a scenario would progress to a zirconium fire is not deemed credible.5.1.3 Consequences of Other Analyzed Events 5.1.3.1 Loss of Spent Fuel Pool Normal Cooling This analysis assesses the time available to initiate compensatory measures in the event of a loss of spent fuel pool inventory as well as the radiological impact. The initiating event is postulated to be an external event that results in a prolonged loss of all Alternating Current (AC) power. In this scenario, there is no active cooling of the SFP, nor is there the ability to maintain SFP water inventory with normal plant systems. This evaluation determined that 15.4 months following shutdown, the time for SFP cooling water inventory to reach 212 degrees Fahrenheit will be 74 hours8.564815e-4 days <br />0.0206 hours <br />1.223545e-4 weeks <br />2.8157e-5 months <br />, and the total time from the loss of cooling to boil off SFP cooling water inventory to 3 feet above the top of the fuel assemblies will be 16 days.Although no fuel damage is expected while the water level remains above the top of the fuel, a SFP cooling water level of 3 feet above the top of the fuel was chosen for ease of comparison to the corresponding information contained in NUREG-1 738. Three feet of water continues to provide sufficient shielding from radiation to any personnel involved in responding to the event. Due to the slow progression rate of SFP water boil-off, adequate time will be available to restore cooling or makeup, either through restoration of normal systems or through readily available mitigation measures, without significant radiological consequences for plant workers in the Reactor Building.5.1.3.2 Radioactive Waste Handling Accident This analysis evaluated the drop of a high integrity container (HIC). The accident evaluated the drop of the largest liner containing the highest concentration of radioactive materials (dewatered resin containing 19,415 curies of 25 various radionuclides representing the highest activity waste at the facility).

The calculation postulates that the container is dropped at a location 250 meters (820 feet) from the closest site boundary with subsequent BVY 14-033 / Attachment 1 / page 5 of 14 container failure with 1% of the liner contents released and 0.5% of the release becoming aerosolized and carried in the direction of the closest Site Boundary.

The resulting two hour integrated dose at the Site Boundary is projected to be 16.1 millirem TEDE, which is below the EAB limit of 1 rem TEDE.5.2 Comparison to NUREG-1738 Industry Decommissioning Commitments and Staff Decommissioning Assumptions Although the limited scope of design and beyond design basis accidents that remain applicable to VY justify a reduction in the necessary scope of emergency response capabilities, ENO also evaluated the industry decommissioning commitments (IDCs) and staff decommissioning assumptions (SDAs) contained in NUREG-1738 (Reference 9).NUREG-1738 contains the results of the NRC staff's evaluation of the potential accident risk in SFPs at decommissioning plants in the United States. As stated therein, the study was undertaken to support development of a risk-informed technical basis for reviewing exemption requests and a regulatory framework for integrated rulemaking.

The NRC staff performed analyses and sensitivity studies on evacuation timing to assess the risk significance of relaxed offsite emergency preparedness requirements during decommissioning.

The staff based its sensitivity assessment on the guidance in Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment In Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" (Reference 10). The staff's analyses and conclusions apply to decommissioning facilities with SFPs that meet the design and operational characteristics assumed in the risk analysis.The study found that the risk at decommissioning plants is low and well within the Commission's Safety Goals. The risk is low because of the very low likelihood of a zirconium fire (resulting from a postulated irrecoverable loss of SFP cooling water inventory) even though the consequences from a zirconium fire could be serious.The study provided the following assessment: "The staff found that the event sequences important to risk at decommissioning plants are limited to large earthquakes and cask drop events. For emergency planning (EP) assessments, this is an important difference relative to operating plants where typically a large number of different sequences make significant contributions to risk. Relaxation of offsite EP a few months after shutdown resulted in only a "small change" in risk, consistent with the guidance of RG 1.174. Figures ES- 1 and ES-2 [in NUREG- 1738] illustrate this finding. The change in risk due to relaxation of offsite EP is small because the overall risk is low, and because even under current EP requirements, EP was judged to have marginal impact on evacuation effectiveness in the severe earthquakes that dominate SFP risk. All other sequences including cask drops (for which emergency planning is expected to be more effective) are too low in likelihood to have a significant impact on risk.For comparison, at operating reactors, additional risk-significant accidents for which EP is expected to provide dose savings are on the order of lx10-5 per year, while for decommissioning facilities, the largest contributor for which EP would provide dose savings is about two orders of magnitude lower (cask drop sequence at 2x10-7 per year)." The Executive Summary in NUREG-1738 states, in part, "the staff's analyses and conclusions apply to decommissioning facilities with SFPs that meet the design and operational characteristics assumed in the risk analysis.

These characteristics are identified in the study as IDCs and SDAs.

BVY 14-033 / Attachment 1 / page 6 of 14 Provisions for confirmation of these characteristics would need to be an integral part of rulemaking." The IDCs and SDAs are listed in Tables 4.1-1 and 4.1-2, respectively, of NUREG-1738. Tables 3 and 4 of Reference 2 identify how the VY SFP meets or compares with each of these IDCs and SDAs.5.3 Consequences of a Beyond Design Basis Earthquake In June 2013, a draft study, entitled "Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark 1 Boiling Water Reactor," was published for public comment (Reference 11). The purpose of the consequence study was to determine if accelerated transfer of older, colder spent fuel from the SFP at a reference plant to dry cask storage significantly reduces risks to public health and safety. The specific reference plant used for the study was a General Electric (GE) Type 4 BWR with a Mark I containment.

VY is a GE BWR/4 with a Mark I containment.

The study states: "Past risk studies have shown that storage of spent fuel in a high-density configuration is safe and risk of a large release due to an accident is very low. This study's results are consistent with earlier research conclusions that spent fuel pools are robust structures that are likely to withstand severe earthquakes without leaking. The NRC continues to believe, based on this study and previous studies that spent fuel pools protect public health and safety." The study also estimated that the likelihood of a radiological release from the SFP resulting from the selected severe seismic event analyzed in the study was on the order of one time in 10 million years or lower. The study analyzed two cases for each scenario:

one where mitigation measures of 10 CFR 50.54(hh)(2) were credited, and one where they were not used or were unsuccessful.

It showed that successful mitigation reduces the likelihood of a release and that the likelihood of a release was equally low for both high- and low-density loading in the SFP.5.4 Permanently Defueled Emergency Plan The VY PDEP is provided as Attachment 2 of this submittal for NRC review and approval.

The PDEP describes the station's plan for responding to emergencies that may arise at VY while in a permanently shutdown and defueled configuration.

The PDEP was developed considering the guidance contained within Attachment 1 of Draft NSIR/DPR-ISG-02, Interim Staff Guidance,"Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants" (Reference 15).The analyses of the potential radiological impact of accidents while the plant is in a permanently defueled condition indicate that no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary.

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 2). Therefore, the proposed PDEP states that notification of an emergency declaration will be made to State authorities within 60 minutes of an emergency declaration or change in classification.

Based on the results of the accident analysis, a 60-minute notification time and reduced scope of offsite and onsite emergency response plans can be implemented without undue risk to public health and safety, commensurate with the reduced offsite radiological consequences associated with the defueled and decommissioning status of the plant.In the event of a large area fire, deliberate attack or other rapidly developing beyond design basis events, the rapid deployment of offsite resources, including law enforcement, ambulance, and fire/rescue services may be requested by the station to assist with the onsite response.

These BVY 14-033 / Attachment 1 / page 7 of 14 requests would be made via direct contact with local law enforcement using established communications methods, including the 911 system.The PDEP addresses the applicable regulations contained in 10 CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities" and is consistent with the applicable guidance established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Reference

12) that remain applicable after the previously requested exemptions are approved (Reference 2).5.5 Permanently Defueled Emergency Action Levels The current VY EAL scheme, based on the guidance presented in NEI 99-01, Rev. 5 was approved by the NRC on June 26, 2009 (Reference 13).Attachment 3 provides the proposed Permanently Defueled EAL Bases Document, Rev. 0, containing the site-specific technical bases for the proposed Permanently Defueled EAL scheme.The EALs that comprise the proposed Permanently Defueled EAL scheme are also presented in the matrix provided in Attachment 4.5.5.1 Differences and Deviations Attachment 5 provides a cross-reference between each generic EAL contained in NEI 99-01, Revision 6 (Reference

4) and the proposed Permanently Defueled EALs. Differences and deviations are identified in accordance with the guidance contained in NRC Regulatory Issue Summary (RIS) 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, Dated January 2003," (and Supplements)(Reference 14). As discussed in RIS 2003-18, Supplement 1, dated July 13, 2004, differences and deviations are defined as follows: "A difference is an EAL change where the basis scheme guidance (NUREG, NUMARC, NEI) differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative reformatting of site-specific EALs." An explanation for each difference between the Permanently Defueled EALs and the guidance presented in NEI 99-01, Rev. 6 is included in Attachment

5. The differences do not alter the meaning or intent of the Initiating Condition or EAL."A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety- related equipment, etc.)." 5.5.2 Operating Modes and Applicability The proposed Permanently Defueled EALs are only applicable to the permanently defueled condition, with all irradiated fuel permanently removed from the reactor vessel and following 15.4 months of decay of the spent fuel.

BVY 14-033 / Attachment 1 / page 8 of 14 5.5.3 State and Local Government Review of Proposed Changes State and local emergency management officials are advised of EAL changes that are implemented.

Following NRC approval and prior to implementation, VY will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR Part 50, Appendix E, Section IV.B.1.5.6 Summary On September 23, 2013, ENO submitted a notification of permanent cessation of power operations pursuant to 10 CFR 50.82(a)(1)(i), stating that ENO has decided to permanently cease power operation of VY at the end of the current operating cycle (Reference 1). Upon docketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i))

and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel.This proposed amendment would revise the emergency plan and the EAL scheme to reflect the permanently defueled condition following 15.4 months of decay of the spent fuel. The new emergency plan and EAL scheme are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2, and are predicated on approval of exemptions (Reference 2).6. REGULATORY EVALUATION The proposed PDEP and Permanently Defueled EAL scheme are predicated on approval of requests for exemptions from portions of 10 CFR 50.47(b);

10 CFR 50.47(c)(2);

and 10 CFR Part 50, Appendix E, Section IV, previously submitted in Reference

2. Therefore, the proposed PDEP does not meet all the standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E.Upon approval of the requested exemptions, the emergency plan, as revised, will continue to meet the remaining applicable requirements in 10 CFR Part 50, Appendix E and the planning standards of 10 CFR 50.47(b).6.1 Applicable Regulatory Requirements and Guidance 10 CFR 50.47, "Emergency Plans," sets forth emergency plan requirements for nuclear power plant facilities.

The regulations in 10 CFR 50.47(a)(1

)(i) state, in part: "...no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." 10 CFR 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency.

Planning Standard (4) of this section requires that a licensee's emergency response plan contain the following:

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

BVY 14-033 / Attachment 1 / page 9 of 14 10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the changes reduce the effectiveness of the plan. This regulation states the following:

The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b).Section IV.B.1 of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part: The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring.

By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant.Section IV.B.2 of Appendix E states that: "A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change."Section IV.C.1 of Appendix E requires each emergency plan to define the emergency classification levels that determine the extent of the participation of the emergency response organization.

The emergency classification levels include: (1) notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency.

EALs are used by plant personnel in determining the appropriate emergency classification level to declare.In November 2012, NEI published NEI 99-01, Revision 6 (Reference 4). The EAL scheme changes being requested herein are based on Revision 6 to NEI 99-01. NRC endorsed NEI 99- 01, Revision 6, by letter dated March 28, 2013 (Reference 5). The analyses of the potential radiological impact of accidents while the plant is in a permanently defueled condition indicate that no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary.

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 2). Therefore, the Permanently Defueled EALs, detailed in NEI 99-01, Revision 6, will be adopted, with certain differences and deviations.

Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC before implementation.

Draft NSIR/DPR-ISG-02, Interim Staff Guidance, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants" (Reference

15) was issued for public comment on BVY 14-033 / Attachment 1 / page 10 of 14 January 10, 2014 and contains guidance for NRC staff evaluation of decommissioning emergency plans.The proposed amendment is being submitted to the NRC pursuant to 10 CFR 50.90, for the purpose of revising the VY SEP in order to establish a plan appropriate for a permanently defueled facility and to implement a Permanently Defueled EAL scheme, predicated on approval of Reference

2.6.2 Precedence

Similar changes to the emergency plan and the associated EAL scheme were approved by NRC for the Zion station as it transitioned from an operating plant to a decommissioned facility, as described in References 16 and 17.Requests for the Haddam Neck Plant (Reference 18), the La Crosse Boiling Water Reactor (LACBWR) facility (Reference 19), Maine Yankee (Reference

20) and Yankee Rowe (Reference 21), were approved exempting each plant from notifying responsible state and local governmental agencies within 15 minutes after declaring an emergency by increasing the notification time to 60 minutes.6.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.92, Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c).

These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2)create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.The proposed changes would revise the Vermont Yankee Nuclear Power Station (VY) site emergency plan (SEP) and emergency action level (EAL) scheme commensurate with the hazards associated with a permanently shutdown and defueled facility.The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.The proposed changes to the emergency plan and EAL scheme do not impact the function of plant structures, systems, or components (SSCs). The proposed changes do not affect accident initiators or precursors, nor does it alter design assumptions.

The proposed changes do not prevent the ability of the on-shift staff and emergency response organization (ERO) to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition.

The probability of occurrence of previously evaluated accidents is not increased, since most previously analyzed accidents can no longer occur and the probability of the few remaining credible accidents are unaffected by the proposed amendment.

BVY 14-033 / Attachment 1 / page 11 of 14 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response:

No.The proposed changes reduce the scope of the emergency plan and EAL scheme commensurate with the hazards associated with a permanently shutdown and defueled facility.

The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced.

Also, the proposed changes do not result in a change to the way that the equipment or facility is operated so that no new or different kinds of accident initiators are created.Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

No.Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the emergency plan and EAL scheme and do not impact operation of the plant or its response to transients or accidents.

The change does not affect the Technical Specifications.

The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes.Safety analysis acceptance criteria are not affected by the proposed changes. The revised SEP will continue to provide the necessary response staff with the proposed changes.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

6.4 Conclusion

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.6.5 Environmental Considerations This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

BVY 14-033 / Attachment 1 / page 12 of 14 (i) The amendment involves no significant hazards consideration.

As described in Section 6.3 of this evaluation, the proposed changes involve no significant hazards consideration.(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.(iii) There is no significant increase in individual or cumulative occupational radiation exposure.The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.Based on the above, ENO concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

7. REFERENCES

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

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," BVY 14-009, dated March 14, 2014 (ML14080A141) (TAC No. MF3614)3. Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," dated February 22, 2008. (ML080450149)

4. Nuclear Energy Institute (NEI) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012. (ML12326A805)

5. Letter, Mark Thaggard (USNRC) to Susan Perkins-Grew (NEI), "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November, 2012 (TAC No. D92368)," dated March 28, 2013. (ML12346A463)

6. U.S. Environmental Protection Agency, "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment, dated March 2013 (PAG Manual)7. Letter, Entergy Nuclear Operations, Inc. to USNRC, 'Technical Specifications Proposed Change No. 306, Eliminate Certain ESF Requirements during Movement of Irradiated Fuel," BVY 13-097, dated November 14, 2013 (ML13323A516) (TAC No. MF3068)

BVY 14-033 / Attachment 1 / page 13 of 14 8. Commission Paper SECY-99-168, Improving Decommissioning Regulations for Nuclear Power Plants, dated June 30, 1999 9. NUREG-1738, 'Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," dated February 2001 10. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment In Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" 11. USNRC, "Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor" (Draft Report for Comment) June 2013 (ML13133A132)

12. NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, published November 1980 13. Letter USNRC to VYNPS, "Vermont Yankee Nuclear Power Station -Safety Evaluation for Emergency Action Levels (TAC No. MD9157)", dated June 16, 2009 14. NRC Regulatory Issue Summary 2003-18, "Use of Nuclear Energy Institute (NEI)99-01, Methodology for Development of Emergency Action Levels, Revision 4, Dated January 2003," and Supplements. (ML032580518, ML041550395 and ML051450482)

15. Draft NSIR/DPR-ISG-02, Interim Staff Guidance, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants" 16. Letter, USNRC to Zion Nuclear Power Station, Unit Nos. 1 and 2, "Request For Approval of Defueled Station Emergency Plan and Exemption from Certain Requirements of 10 CFR 50.47, "Emergency Plans"- Zion Nuclear Power Station, Unit Nos. 1 and 2 (TAC NOS MA5253 and MA554)," dated August 31, 1998, 17. Letter, USNRC to Zion Nuclear Power Station, Unit Nos. 1 and 2, "Emergency Action Level Revisions for Zion Nuclear Power Station (TAC Nos. J00327 and J00328)," dated February 25, 2008 (ML072680350)

18. Letter, USNRC to Connecticut Yankee Atomic Power Company, "Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E, and Title 10 of the Code of Federal Regulations Part 50.47 for the Haddam Neck Plant (TAC NO. L24663)," dated March 18, 2013. (ML13064A374)

19. Letter, USNRC to Dairyland Power Cooperative, "La Crosse Boiling Water Reactor-Issuance of Exemption From Certain Emergency Planning Requirements (TAC NO. J00438)," dated July 31, 2013. (ML1 3008A565)20. Letter, USNRC to Maine Yankee Atomic Electric Company, "Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E, and Title 10 of the Code of Federal Regulations Part 50.47 for the Maine Yankee Atomic Power Station (TAC NO. L24661)," dated May 2, 2013.(ML1 3112A842)

BVY 14-033 / Attachment 1 / page 14 of 14 21. Letter, USNRC to Yankee Rowe Plant ISFSI, "Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E, and Title 10 of the Code of Federal Regulations Part 50.47 for the Yankee Rowe Plant (TAC NO. L24662)," dated May 7, 2013. (ML13121A560)

BVY 14-033 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Permanently Defueled Emergency Plan PERMANENTLY DEFUELED EMERGENCY PLAN ENTERGY VERMONT YANKEE VERNON, VERMONT REVISION 0 PREPARER: REVIEWED: APPROVED: APPROVED: Emergency Planning Manager (Print/Sign)

On-Site Safety Review Committee (Print/Sign)

General Manager (Print/Sign)

Site Vice President (Print/Sign)

Date Date Date Date Effective Date ENTERGY VERMONT YANKEE PERMANENTLY DEFUELED EMERGENCY PLAN REVISION

SUMMARY

DATE REVISION DESCRIPTION TBD 0 The analyses of the potential radiological impact of accidents while the plant is in a permanently defueled condition indicate that no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary.

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, the Permanently Defueled Emergency Plan adequately addresses the risk associated with VY's permanently defueled condition and continues to provide adequate protection for plant personnel and the public. Exemptions from the applicable portions of 10 CFR 50.47(b), Appendix E to 10 CFR Part 50 and 10 CFR 50.47(c)(2) were previously approved by the Nuclear Regulatory Commission (NRC).Permanently Defueled Emergency Plan Revision 0 Revision Summary Page i of i Entergy Vermont Yankee TABLE OF CONTENTS

1.0 INTRODUCTION

..................................................................................................

I 1 .1 .P u rp o se ...........................................................................................................

1 1 .2 .S c o p e ..............................................................................................................

1 2.0 DEFINITIONS

...................................................................................................

2 3.0

SUMMARY

OF EMERGENCY PLAN ....................................................................

4 3.1. Overview of Permanently Defueled Emergency Plan ..................................

4 3.2. Objectives

..................................................................................................

4 3.3. Actions in an Emergency

.............................................................................

5 3.4. Emergency Response Facilities

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6 3.5. Mobilization

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6 3.6. State and Local Government Notification and Response ............................

6 3.7. Federal Government Notification and Response .........................................

7 3.8. Technical Support .......................................................................................

7 3.9. Mitigation of Consequences of Beyond Design Basis Events .....................

7 4.0 SITE DESCRIPTION

.............................................................................................

8 4.1. Facility Description

.....................................................................................

8 4.2. Area Characteristics and Land Use .............................................................

8 5.0 EMERGENCY CLASSIFICATION SYSTEM ......................................................

10 5.1. Unusual Event ..........................................................................................

10 5 .2 .A le rt ...............................................................................................................

1 0 5.3. Emergency Classification System Review by State Authorities

.................

11 6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT

..............................

12 6.1. Control Room ............................................................................................

12 6.2. Assessment Capability

...............................................................................

12 6.2.1. Process Monitors .....................................................................

13 6.2.2. Radiological Monitors ...............................................................

13 6.2.3. Meteorological Capability

...........................................................

13 6.2.4. Fire Detection and Suppression Equipment

..............................

14 6.2.5. Assessment Facilities and Equipment

.......................................

14 7.0 COMMUNICATIONS

...........................................................................................

15 7.1. InForm Notification System ........................................................................

15 7.2. Nuclear Alert System ................................................................................

15 7.3. ERO Notification System ..........................................................................

15 7.4. Mobile UHF Radio System ........................................................................

15 7.5. Plant Intercom System ..............................................................................

16 7.6. NRC Telephone System .............................................................................

16 7.7. Commercial Telephone System ...............................................................

16 Permanently Defueled Emergency Plan Revision 0 Table of Contents Page i of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

7.8. Emergency

Power Supply for Communications

........................................

16 8.0 ORGANIZATION

................................................................................................

18 8.1. Normal Plant Organization

........................................................................

18 8.1.1. Shift Manager/Emergency Director ...........................................

18 8.1.2. Non-Certified Operator .............................................................

19 8.1.3. Radiation Protection Technician

................................................

19 8 .1.4 .S ecurity ...................................................................................

..19 8.2. Emergency Response Organization

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20 8.2.1. Technical Coordinator

...............................................................

20 8.2.2. Radiation Protection Coordinator

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21 8.2.3. Extensions of the Vermont Yankee Emergency Response O rganization

............................................................................

21 8.2.4. Recovery Organization

.............................................................

22 8.3. Coordination with State Government Authorities

.......................................

23 9.0 EMERGENCY RESPONSE .................................................................................

26 9.1. Emergency Condition Recognition and Classification

...............................

26 9.2. Activation of the Emergency Response Organization

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26 9.2.1. Unusual Event Response .........................................................

26 9.2.2. Alert Response .....................................

27 9.3. Emergency Termination Criteria ...............................................................

28 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES ..................

31 10.1. Radiological Assessment

..........................................................................

31 10.1.1. Initial Radiological Dose Projection

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31 10.2. Radiological Exposure Control .................................................................

31 10.3. Protective Measures ................................................................................

31 10.3.1. Site Personnel Accountability

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31 10.3.2. Site Egress Control Methods ....................................................

32 10.3.3. Decontamination Capability

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32 10.3.4. Use of Onsite Protective Equipment and Supplies ....................

32 10 .3.5. Fire Fighting ............................................................................

..32 10.4. Aid to Affected Personnel

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33 10.4.1. Medical Treatment

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33 10.4.2. Medical Transportation

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33 10.5. Protective Actions for Onsite Personnel

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33 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION

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35 11.1. Emergency Notification

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35 11.2. Public Information

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35 12.0 MAINTAINING EMERGENCY PREPAREDNESS

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36 12.1. D rills and E xercises ...................................................................................

36 Permanently Defueled Emergency Plan Revision 0 Table of Contents Page ii of vi Entergy Vermont Yankee TABLE OF CONTENTS (Continued) 12.2.12.3.12.4.12.5.12.1.1. Radiation Emergency Exercises and Drills ...............................

36 12.1.2. Communication Tests ...............................................................

36 12.1.3. Augmentation Capability Drills ..................................................

37 12.1.4. Fire Drills ...................................................................................

37 12.1.5. Medical Drills ............................................................................

37 12.1.6. Radiological Monitoring Drills ....................................................

37 12.1.7. Health Physics Drills .................................................................

38 12.1.8. Security Drills ............................................................................

38 12.1.9. Scenarios

.................................................................................

38 12.1.10. Evaluation of Exercises

.............................................................

39 12.1.11. Emergency Plan Audit ...............................................................

39 Training ....................................................................................................

39 Review and Updating of Plan and Procedures

.........................................

40 Maintenance and Inventory of Emergency Equipment and Supplies ...... 40 Responsibility for the Planning Effort ........................................................

41 Permanently Defueled Emergency Plan Revision 0 Table of Contents Page iii of vi Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

APPENDICES APPENDIX A APPENDIX B APPENDIX C APPENDIX D APPENDIX E Emergency Classification System and Emergency Action Levels Emergency Equipment Environmental Laboratory Analytical and Dosimetry Services Letters of Agreement Index of Emergency Plan Implementing Procedures and Support Plans Page 42 43 46 48 51 Permanently Defueled Emergency Plan Revision 0 Table of Contents Page iv of vi Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

LIST OF TABLES Table 7.1 Table 8.1 Table 10.1 Vermont Yankee Emergency Communications Matrix Minimum On-Shift and ERO Staffing Requirements Emergency Dose Limits Permanently Defueled Emergency Plan Revision 0 Table of Contents Page v of vi Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

LIST OF FIGURES Vermont Yankee Site Normal On-Shift Emergency Organization Notification Plan Figure 4.1 Figure 8.1 Figure 9.1 Permanently Defueled Emergency Plan Revision 0 Table of Contents Page vi of vi Entergy Vermont Yankee

1.0 INTRODUCTION

The Permanently Defueled Emergency Plan (PDEP) describes the station's plan for responding to emergencies that may arise at the Vermont Yankee Nuclear Power Station (VY) while in a permanently shutdown and defueled configuration.

VY has provided certification to the Nuclear Regulatory Commission (NRC) required by 10 CFR 50.82(a)(1)(i) and (ii) that the station has permanently ceased operations and that all fuel has been permanently removed from the reactor vessel. In this configuration, all irradiated fuel is stored in the Independent Spent Fuel Storage Installation (ISFSI) and in the Spent Fuel Pool (SFP). In this condition, no reactor operations can take place and the station is prohibited from emplacement or retention of fuel in the reactor vessel. An analysis of the possible design basis events and consequences is presented in the evaluation of the Updated Final Safety Analysis Report (UFSAR) accident assessment.

This PDEP adequately addresses the risks associated with VY's current conditions.

The analysis of the potential radiological impact of an accident in a permanently defueled condition indicates that any releases beyond the Site boundary are below the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment dated March 2013 (PAG Manual).Exposure levels, which warrant pre-planned response measures, are limited to onsite areas. For this reason, radiological emergency planning is focused onsite.1.1. Purpose The purpose of the PDEP is to assure an adequate level of preparedness by which to cope with a spectrum of emergencies that could be postulated to occur, including the means to minimize radiation exposure to plant personnel.

This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

1.2. Scope

The PDEP has been developed to respond to potential radiological emergencies at VY considering the permanently shutdown and defueled status. Because there are no postulated accidents that would result in dose consequences that are large enough to require offsite emergency planning, the overall scope of this plan delineates the actions necessary to safeguard onsite personnel and minimize damage to property.The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." Exemptions to selected portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR Part 50, Appendix E were previously approved by the NRC.Permanently Defueled Emergency Plan Revision 0 Page 1 of 53 Entergy Vermont Yankee

2.0 DEFINITIONS

Alert -Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Assessment Actions -Those actions which are taken to effectively define the emergency situation necessary for decisions on specific emergency measures.Code Red -A Security related contingency requiring the activation of the Security Response Team. This contingency shall, as a minimum cause an Unusual Event to be announced.

Committed Dose Equivalent (CDE) -The dose equivalent to organs or tissues of reference (e.g., thyroid) that will be received from an intake of radioactive material by an individual during the 50 year period following the intake.Confinement Boundary -The barrier(s) between areas containing radioactive substances and the environment.

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

Emergency Action Levels -A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given emergency classification level.Emergency Classification

-One of a set of names or titles established by the US Nuclear Regulatory Commission for grouping off-normal events or conditions according to (1)potential effects or consequences, and 2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are: UNUSUAL EVENT and ALERT.Emergency Implementing Procedure

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

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

Emergency Response Organization

-Organization comprised of assigned Vermont Yankee personnel who would respond and assist in a classified emergency situation.

Gai-Tronics

-An intra-site station operation and public address system which consists of speakers and microphones located in areas vital to the operation of the station. The Permanently Defueled Emergency Plan Revision 0 Page 2 of 53 Entergy Vermont Yankee system has four channels which provide separate and independent page and intercommunication capabilities.

Hostile Action -An act toward an NPP or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP.Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area).Independent Spent Fuel Storaae Installation (ISFSI) -A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.Initiating Condition

-An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Notification of Unusual Event -Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Also referred to as an Unusual Event.Prolected Dose -The amount of radiation dose estimated at the onset of any accidental radiological release. It includes all the radiation dose the individual would receive for the duration of the release assuming that no protective measures were undertaken.

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

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

Site -That property within the fenced boundary of Vermont Yankee which is owned by the Company.Total Effective Dose Equivalent (TEDE) -The sum of the deep dose equivalent from external sources and the committed effective dose equivalent from internal exposures.

Permanently Defueled Emergency Plan Revision 0 Page 3 of 53 Entergy Vermont Yankee 3.0

SUMMARY

OF EMERGENCY PLAN 3.1. Overview of Permanently Defueled Emergency Plan In the event of an emergency at the plant, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of plant personnel.

This plan describes the organization and responsibilities for implementing emergency measures.

It describes interfaces with Federal, State of Vermont and local organizations which may be notified in the event of an emergency, and may provide assistance.

Emergency services are provided by local public and private entities.

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

Law enforcement support services are provided by local, county, state, and federal law enforcement authorities, as appropriate.

Ambulance service is provided by Rescue, Inc. Medical services are provided by Brattleboro Memorial Hospital.Because there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning, emergencies are divided into two classifications:

1) Notification of Unusual Event (Unusual Event) and 2) Alert. This classification scheme has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans. According to the EPA PAG Manual, "Emergency Planning Zones (EPZs) are not necessary at those facilities where it is not possible for PAGs to be exceeded off-site." VY is responsible for planning and implementing emergency measures within the Site.This plan is provided to meet that responsibility.

To carry out specific emergency measures discussed in this Plan, detailed emergency plan implementing procedures are established and maintained.

In addition to the description of activities and steps that can be implemented during an emergency, this Plan also provides a general description of the steps taken to recover from an emergency situation.

It also describes the training, drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

3.2. Objectives

The basic objectives of this plan are: 1) To establish a system for identification and classification of the emergency condition and initiation of response actions;2) To establish an organization for the direction of activity within the plant to limit the consequences of the incident;Permanently Defueled Emergency Plan Revision 0 Page 4 of 53 Entergy Vermont Yankee

3) To establish an organization for control of surveillance activities to assess the extent and significance of any uncontrolled release of radioactive material;4) To identify facilities, equipment and supplies available for emergency use;5) To establish an engineering support organization to aid the plant personnel in limiting the consequences of and recovery from an event;6) To establish the basic elements of an emergency recovery program;7) To specify a system for coordination with federal, state, and local authorities and agencies for offsite support organizations;

8) To develop a communications network between the plant and offsite authorities to provide notification of emergency situations;

9) To develop a training and Emergency Plan exercise program to assure constant effectiveness of the plan.3.3. Actions in an Emergency This Plan is activated by the Shift Manager upon identification of an emergency situation based upon Emergency Action Level (EAL) criteria.

The emergency measures described in the subsequent sections and emergency plan implementing procedures are implemented in accordance with the classification and nature of the emergency at the direction of the Shift Manager. Regulatory authorities and offsite support organizations are notified in accordance with this Plan. The Shift Manager has authority and responsibility for control and mitigation of the emergency, including emergency response resources, coordination of radiological assessment activities, and recovery implementation.

If an emergency condition develops, the Shift Manager assumes the role of Emergency Director, including responsibilities for initiating emergency actions to limit the consequences of the incident and to bring the plant into a stable condition.

The individual must: 1) Recognize the emergency condition by observation of EALs;2) Classify the accident in accordance with the emergency classification system;3) Initiate emergency procedure(s) applicable to the event;4) Activate the plant emergency alarm system;5) Notify state authorities in Vermont using the InForm Notification System;6) Notify the NRC using the Emergency Notification System (ENS);Permanently Defueled Emergency Plan Revision 0 Page 5 of 53 Entergy Vermont Yankee

7) Use the notification plan to notify appropriate personnel as set forth in Figure 9.1;and 8) Direct and coordinate all emergency response efforts until overall responsibility is assumed by the Emergency Director.3.4. Emergency Response Facilities The emergency response facilities, which are utilized by the Emergency Response Organization (ERO), are described in Section 6.0. Key site personnel are dispatched to perform accident assessments, implement corrective actions, and analyze accident data.3.5. Mobilization The mobilization scheme is based on the emergency notification system shown in Figure 9.1. The notification system utilizes the plant public address system (Gai-Tronics), dedicated telephone lines, and the ERO notification system to notify and mobilize plant personnel.

The mobilization scheme ensures that specific technical disciplines can be augmented within appropriate time frames. Section 8.2, Figure 8.1 and Table 8.1 outline the minimum staffing requirements for the ERO at VY.3.6. State and Local Government Notification and Response VY's Emergency Plan interfaces with the state emergency response plans of Vermont.Vernon, Vermont, in coordination with the emergency management agencies of Vermont, maintains the capability to communicate on a 24-hour per day basis.VY conveys specific accident information to the State of Vermont using the InForm Notification System.A cooperative arrangement exists among the Vermont State authorities and VY concerning radiological emergency preparedness.

VY's emergency classification system and notification messages are reviewed with the State of Vermont on an annual basis.Permanently Defueled Emergency Plan Revision 0 Page 6 of 53 Entergy Vermont Yankee

3.7. Federal

Government Notification and Response Notification to the NRC is made using the ENS as soon as possible after State notifications and within 60 minutes of event classification or change in classification.

Once notified of an emergency, the NRC evaluates the situation and determines the appropriate NRC response.

Depending on the severity of the accident and the emergency classification declared, the NRC activates their incident response operations in accordance with the NRC Incident Response Plan. If the emergency warrants, the NRC notifies the Federal Emergency Management Agency (FEMA) and other appropriate federal agencies to activate the federal emergency response organization in accordance with the National Response Framework (NRF). The NRF makes available the resources and capabilities of federal agencies to support plant, state and local governments, as necessary to respond to the specific nature of the emergency.

Principal participants are the NRC, FEMA, Department of Energy (DOE), and Environmental Protection Agency (EPA).3.8. Technical Support In the event of an emergency that requires personnel and other support resources beyond those available within the VY organization, augmentation is available from other Entergy facilities and can be requested from various contractors.

Additional technical and manpower support are provided to VY through support plans listed in Appendix E.3.9. Mitigation of Consequences of Beyond Design Basis Events Strategies to mitigate a loss of SFP inventory and prevent a zirconium fire are contained within Appendix G, "Loss of Large Areas of the Plant Due to Fire or Explosion," of PP 7019,"Severe Accident Management Program." Appendix G of PP 7019 describes the equipment, resources (such as water supplies), procedures and strategies in place for movement of any necessary portable equipment that will be relied upon for prevention of a zirconium fire in the SFP. These mitigative strategies were developed as a result of NRC Order on Mitigative Strategies (EA-12-049) and implement the requirements of License Condition 3.N, "Mitigation Strategy License Condition." Permanently Defueled Emergency Plan Revision 0 Page 7 of 53 Entergy Vermont Yankee 4.0 SITE DESCRIPTION

4.1. Facility

Description VY is located on the west bank of the Connecticut River immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. VY consists of a permanently shutdown boiling water reactor having a thermal rated power of 1912 MWt. An ISFSI is located on the plant site. The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Entergy, with the exception of a narrow strip of land between the Connecticut River and the VY property for which it has perpetual rights and easements from the owner, New England Power Company.The 10 CFR Part 50 license for VY no longer authorizes operation of the reactor, emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

4.2. Area Characteristics and Land Use The site is bounded by the Connecticut River (Vernon Pond) on the east, by farm and pasture land mixed with wooded areas on the north and south, and by the town of Vernon on the west. Most of the land around the site is undeveloped.

The developed land is used for agriculture, dairying, and for residential areas within small villages.

The nearest residence is 1,300 feet from the Reactor Building and is one of several west of the site.The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500 feet from the Reactor Building.

The nearest hospital, Brattleboro Memorial, is approximately five (5) miles north-northwest from the site.Permanently Defueled Emergency Plan Revision 0 Page 8 of 53 Entergy Vermont Yankee I., iI LIJ 4 Ver Mont Yac2Lm Nuclear Power Sitation Vernon L..Ib~irIC1t Otl% c-wr Rum llkw<A N 7a inn-p", --F." ---111 1 1- ý --METERS Figure 4.1 Vermont Yankee Site Permanently Defueled Emergency Plan Revision 0 Page 9 of 53 Entergy Vermont Yankee

5.0 EMERGENCY

CLASSIFICATION SYSTEM The emergency classification system covers an entire spectrum of possible radiological and non-radiological emergencies at the VY. The emergency classification system categorizes accidents and emergency situations, according to severity, into two emergency classification levels: Unusual Event and Alert.The incidents leading to each of the emergency classifications are further identified by certain measurable and observable indicators of plant conditions (EALs). EALs addressed in Appendix A aid the operator in recognizing the potential of an incident immediately and assure that the first step in the emergency response is carried out. The classification of the event may change as the conditions change. VY maintains the capability to assess, classify and declare an emergency condition in accordance with site procedures.

EALs and EAL bases were derived from NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors" Rev. 6, for classifying emergencies.

Specifically, Appendix C of NEI 99-01, Rev. 6 contains a set of Initiating Conditions/

EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased operations.

The classification system referenced in NEI 99-01, Rev. 6 has been endorsed by the NRC and provides a standard method for classifying emergencies.

5.1. Unusual

Event EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANT OR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HAS BEEN INITIATED.

NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED UNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.Unusual Event conditions do not cause serious damage to the plant. The purpose of the Unusual Event declaration is to: 1) provide for an increased awareness of abnormal conditions;

2) ensure that the first step in any response later found to be necessary has been carried out; 3) bring the ERO to a state of readiness;

4) to provide for systematic handling of information and decision-making, and 5) augment on-shift personnel, if deemed necessary by the Emergency Director.See Appendix A for a complete list of EALs corresponding to an Unusual Event.5.2. Alert EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANT OR A SECURITY EVENT THAT INVOLVES PROBABLE LIFE THREATENING RISK TO SITE PERSONNEL Permanently Defueled Emergency Plan Revision 0 Page 10 of 53 Entergy Vermont Yankee OR DAMAGE TO SITE EQUIPMENT BECAUSE OF HOSTILE ACTION.ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PAG EXPOSURE LEVELS.The purpose of the Alert declaration is to: 1) activate the Emergency Response Organization to perform event mitigation and radiation monitoring, if required, 2) provide the State of Vermont and the NRC with current information on plant status, and 3) ensure that all necessary resources are being applied to accident mitigation.

Plant responses associated with this event classification assure that sufficient emergency response personnel are mobilized and respond to event conditions.

Actual releases of radioactivity which exceed Technical Specification limits may be involved, thus radiation monitoring and dose projection may be required.See Appendix A for a complete list of EALs corresponding to an Alert.5.3. Emergency Classification System Review by State Authorities The emergency classification system specified above and the EALs presented in Appendix A, are reviewed with the state authorities of Vermont annually.Permanently Defueled Emergency Plan Revision 0 Page 11 of 53 Entergy Vermont Yankee

6.0 EMERGENCY

RESPONSE FACILITIES AND EQUIPMENT Following the declaration of an emergency, the activities of the emergency response organization are coordinated in the Control Room. Descriptions of VY facilities and assessment capabilities are presented below.6.1. Control Room The Control Room is where plant systems and equipment parameters are monitored.

Control Room personnel assess plant conditions, evaluate the magnitude and potential consequences of abnormal conditions, initiate preventative, mitigating and corrective actions and perform notifications.

The Control Room is the onsite center for emergency command and control.The Control Room crew coordinates all phases of emergency response and corrective action required to restore the plant to a safe condition.

Classification and subsequent declaration of the appropriate emergency condition by the Shift Manager results in activation of the ERO. The Control Room staffs attention focuses on mitigating the emergency as the ERO reports and is delegated emergency functions.

When activated, the ERO reports to the Emergency Director to assist the on-shift staff in the assessment, mitigation and response to an emergency and to support the dispatch of emergency teams. The composition of the ERO is addressed in Section 8.2.ERO activation may be modified or suspended if the safety of personnel may be jeopardized by a security event or other event hazardous to personnel.

The Control Room contains communications equipment, emergency radiation monitoring equipment, emergency respiratory devices, and an emergency kit containing protective clothing and other supplies.

The ERO has access to up-to-date technical documentation, including drawings, system information and procedures to enable mitigation planning and support of Control Room staff.A general assembly area for emergency mitigation and radiation protection personnel is maintained.

6.2. Assessment

Capability The activation of the Emergency Plan and the continued assessment of accident conditions require monitoring and assessment capabilities.

The essential monitoring systems needed are incorporated in the EALs specified in Appendix A. This section briefly describes monitoring systems as well as other assessment capabilities.

Permanently Defueled Emergency Plan Revision 0 Page 12 of 53 Entergy Vermont Yankee

6.2.1. Process

Monitors Annunciator and computer alarms are provided for a variety of parameters including the SFP cooling system to indicate SFP level, temperature and pump status.The manner in which process monitors are used for accident recognition and classification is given in the detailed EAL listings in Appendix A.6.2.2. Radiological Monitors A number of radiation monitors and monitoring systems are provided on process and effluent liquid and gaseous lines that serve directly or indirectly as discharge route for radioactive materials.

These monitors, which include Control Room readout and alarm functions, exist in order that appropriate action can be initiated to limit fuel damage and/or contain radioactive material.Specific details on these monitoring systems such as location, type, etc., are contained in the UFSAR.In addition to installed monitoring systems, VY has augmented onsite radiological assessment capability.

6.2.3. Meteorological

Capability The meteorological equipment at the site consists of wind-speed and direction transmitters, signal translators, and recorders.

In addition, the temperature measurement consists of recorders and resistance temperature detectors (RTDs). RTDs are used to monitor ambient temperature and calculate differential temperature.

In addition, VY has the capability to access additional meteorological information through offsite support services.

This information can be forwarded to VY upon request.Permanently Defueled Emergency Plan Revision 0 Page 13 of 53 Entergy Vermont Yankee 6.2.4. Fire Detection and Suppression Equipment The fire protection system has been designed to detect and extinguish potential fires. The system is designed in accordance with the standards of the National Fire Protection Association (NFPA) and recommendations of the Nuclear Electric Insurance Limited (NEIL). Fire detectors are located throughout the plant with alarms and indicators in the Control Room. The fire protection system is described in the Vermont Yankee Fire Protection Program.6.2.5. Assessment Facilities and Equipment Vermont Emergency Management provides reports concerning natural occurrences or severe weather conditions that may affect the plant area. Offsite fire departments of Vernon and Brattleboro notify the plant of any fire which might have an impact on the plant.Local Law Enforcement Agencies notify Plant Security of any situation in the area which might have an impact on the plant.VY maintains an offsite environmental monitoring program. Radiological environmental monitoring stations for the site and surrounding area monitor the environment under normal and accident conditions.

VY has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities.

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

Permanently Defueled Emergency Plan Revision 0 Page 14 of 53 Entergy Vermont Yankee

7.0 COMMUNICATIONS

Various modes of communication are available to plant staff to transmit information within VY and to various locations offsite during normal and emergency conditions.

A summary of the communication systems is defined in the communication matrix provided in Table 7.1 and outlined below.7.1. InForm Notification System The InForm Notification System is located in the Control Room. InForm consists of source and destination computers that take advantage of the internet to send Emergency Notification Forms to the State of Vermont.This system is staffed on a 24-hour basis on both ends -the Control Room and the State Police dispatching points. InForm performs self-checks at frequent intervals and has the ability to notify personnel of any problems identified during the self-check.

InForm is tested monthly between the Control Room and the State Police dispatching points.Backup to the InForm Notification System is the Nuclear Alert System (NAS).7.2. Nuclear Alert System The NAS can be used to notify the State of Vermont of any emergency.

This system is a secure (dedicated) communications arrangement.

This system is staffed on a 24-hour basis in the Control Room and by the State of Vermont.The NAS is tested monthly between the plant and the State agencies.The NAS links the Control Room and the Vermont Emergency Operations Center.Backup to the NAS phone system is the commercial phone system.7.3. ERO Notification System The ERO notification system is the primary means to activate the ERO upon declaration of an emergency, as directed by the Emergency Director.

This system is tested as described in Section 12.1.2.7.4. Mobile UHF Radio System The Mobile UHF Radio System is utilized as a primary means of communications for security personnel; it is the alternate means of communications between the Control Room and onsite response teams. The System consists of UHF repeaters with high gain antennas.

These repeaters are activated by base radio stations.

Also, the portable units activate the repeater.

In the event the repeater fails, a "talk around" feature allows Permanently Defueled Emergency Plan Revision 0 Page 15 of 53 Entergy Vermont Yankee continued communications between portable units. This system is tested daily through operational use of the system.Security also has the capability to contact the primary local law enforcement agency patrol vehicle(s), as defined in the VY Physical Security Plan, that are located in close proximity to the plant via radio.7.5. Plant Intercom System The Intercom System (Gai-Tronics) is located in many areas throughout the plant, including the Control Room and Security Gates. This system consists of five channels and is utilized as a paging system and for communications with the refuel bridge. During emergency situations, the system is used as the primary means for: (1) notifying plant personnel of the emergency, (2) coordinating the activities of onsite response teams with the Control Room;and (3) calling for any missing or unaccounted for personnel that may be in the plant. This system is in continuous daily use.7.6. NRC Telephone System The NRC has utilized the Federal Telecommunications System (FTS) telephone network for its emergency telecommunications system. The FTS system provides a separate (public cannot access) government telephone network which avoids potential public telephone blockage which may occur in the event of a major emergency.

The ENS utilizes an FTS line which exists between the NRC Operations Office in Rockville, Maryland and the Control Room. Emergency notification, plant status information and radiological information are communicated via the ENS. The ENS is tested daily by the NRC and has a 24-hour manning capability at both organizations.

7.7. Commercial

Telephone System The commercial telephone system is used as a primary and alternate means of communications for notification and coordination.

For conditions involving telephone company equipment blockage in the local area, alternate external telephone line arrangements have been made available to the plant. This system is tested daily through operational use of the system.7.8. Emergency Power Supply for Communications Currently there are several telephone and other emergency communication channels (Gai-Tronics, radio network, and microwave) located within the plant that are connected to an emergency or redundant power supply. All emergency communications (including all phones) located within the plant are connected to an emergency or redundant supply.There are power fail phones located in the Control Room, which will automatically activate if power is lost to the internal telephone system.Permanently Defueled Emergency Plan Revision 0 Page 16 of 53 Entergy Vermont Yankee TABLE 7.1 VERMONT YANKEE EMERGENCY COMMUNICATIONS MATRIX CR Offsite and Site Boundary Monitors 1, 3 Nuclear Regulatory Commission 1,4 State Police (VT) 1, 2, 8 State EOCs (VT) 1, 2, 7, 8 Vermont Yankee Plant Security 1, 3, 5 Vermont Yankee Emergency Response Personnel 1,6 KEY 1 Commercial Telephone System 2 NAS 3 Mobile UHF Radio System 4 ENS (FTS)5 Gai-Tronics 6 ERO notification system 7 Southwest Fire Radio 8 InForm Permanently Defueled Emergency Plan Revision 0 Page 17 of 53 Entergy Vermont Yankee

8.0 ORGANIZATION

This section describes how the normal plant and engineering support organization transform into an emergency response organization to effectively deal with any incident at VY.8.1. Normal Plant Organization The personnel and resources of VY's normal plant and management organization consist of the onsite facility organization supported by the engineering and management organizations located offsite. The relationship and content of these onsite and offsite organizations are specified in the plant Technical Specifications, Technical Requirements Manual or Quality Assurance Manual.The minimum staff required to conduct routine and immediate emergency mitigation is maintained at the station. During normal conditions, the minimum staff on duty at the plant during all shifts consists of one (1) Shift Manager, one (1) Non-Certified Operator, one (1)Radiation Protection Technician and security personnel as indicated in Figure 8.1 and Table 8.1. The responsibility for monitoring the status of the plant and approving all onsite activities is assigned to the Shift Manager. When an abnormal situation becomes apparent, the Shift Manager shall assume the position of Emergency Director once the emergency classification has been made. Additional personnel are available on an on-call basis to respond to plant emergencies.

8.1.1. Shift

Manager/Emergency Director The Shift Manager is at the station 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the senior management position at the station during off-hours.

The Shift Manager shall assume the position of Emergency Director once the emergency classification has been made.This position is responsible for monitoring conditions and approving all onsite activities and has the requisite authority, management ability, technical knowledge, and staff to manage the site emergency and recovery organization.

The Emergency Director is responsible for the direction of the total emergency response and has the company authority to accomplish this responsibility.

The Emergency Director cannot delegate the following responsibilities:

1. Classification of event 2. Approval of emergency notification (although the task of making notifications may be delegated)

3. Authorization of radiation exposures in excess of 10 CFR Part 20 limits Other responsibilities assumed by the Emergency Director include: Permanently Defueled Emergency Plan Revision 0 Page 18 of 53 Entergy Vermont Yankee

1. Notification of the emergency classification to the NRC and State of Vermont 2. Management of available station resources 3. Initiation of mitigating actions 4. Initiation of corrective actions 5. Initiation of onsite protective actions 6. Decision to call for offsite police, fire or ambulance assistance

7. Augment the ERO staff as deemed necessary 8. Coordinate Security activities

9. Terminate the emergency condition when appropriate

10. Performance of initial Dose Assessment

11. Maintain a record of event activities 8.1.2. Non-Certified Operator The Non-Certified Operator performs system and component manipulations.

The organizational relationship to the Shift Manager/Emergency Director is the same during normal and abnormal situations.

8.1.3. Radiation

Protection Technician The Radiation Protection Technician is available to monitor personnel exposure, determine if radiological conditions preclude access to areas necessary to maintain SFP cooling, and to provide timely field survey results, if necessary.

8.1.4. Security

Security staffing is maintained in accordance with the Security Plan. The Security Force will report to the Emergency Director when implementing the PDEP.During non-security events, Security will activate the station ERO callout system and perform accountability at the direction of the Emergency Director.Permanently Defueled Emergency Plan Revision 0 Page 19 of 53 Entergy Vermont Yankee

8.2. Emergency

Response Organization The VY ERO is activated at an Alert classification.

However, it can be activated in part or in whole at the discretion of the Emergency Director for an Unusual Event.Plans and procedures are in place to ensure the timely activation of the ERO. The goal of the ERO is to augment the on-shift staff within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of an Alert classification.

Due to the slow rate of the postulated event scenarios in the accident analysis and the ability of the on-shift staff to implement the Emergency Plan, the ERO augmentation goal of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is appropriate.

The minimum augmented staff consists of a Technical Coordinator and a Radiation Protection Coordinator.

Augmented staff provides the technical expertise required to assist the Emergency Director.

The on-shift staff is augmented by additional personnel that report as directed after receiving notification of an emergency requiring augmented staff.Designated members of the on-shift staff fulfill roles within the ERO appropriate with their training and experience.

For example, Radiation Protection personnel would be expected to undertake radiation protection activities, Security personnel would undertake security activities, Engineering personnel would focus on plant assessment and technical support, and Operations personnel would focus on plant operations.

The VY ERO is illustrated in Figure 8.1.8.2.1. Technical Coordinator The Technical Coordinator reports to the Emergency Director.

During an emergency, the responsibilities of the Technical Coordinator include: 1. Evaluate technical data pertinent to plant conditions

2. Augment the emergency staff as deemed necessary 3. Recommend mitigating and corrective actions 4. Direct search and rescue operations

5. Coordinate maintenance and equipment restoration

6. Establish and maintain communications as desired by the Emergency Director 7. Maintain a record of event activities Permanently Defueled Emergency Plan Revision 0 Page 20 of 53 Entergy Vermont Yankee

8.2.2. Radiation

Protection Coordinator The Radiation Protection Coordinator reports to the Emergency Director.

During an emergency, the responsibilities of the Radiation Protection Coordinator include: 1. Monitor personnel accumulated dose 2. Advise the Emergency Director concerning Radiological EALs 3. Augment the emergency staff as deemed necessary 4. Direct radiological monitoring and analysis 5. Dose Assessment

6. Establish and maintain communications as desired by the Emergency Director 7. Maintain a record of event activities

8.2.3. Extensions

of the Vermont Yankee Emergency Response Organization 8.2.3.1. Local Services Arrangements have been made for the extension of the ERO's capability to address emergencies.

The following arrangements are in place through letters of agreement for ambulance services, treatment of contaminated and injured patients, fire support services, and law enforcement response as requested by the station: 1. Transportation of injured personnel using an ambulance service;2. Treatment of radioactively contaminated and injured personnel at a local support hospital (Brattleboro Memorial) as specified in the local support hospital plans; and 3. Fire support services by the Vernon and Brattleboro Fire Departments and the Tri-State and Southwestern Fire Mutual Aid Networks.4. Law enforcement support services provided by local, county, state, and federal law enforcement authorities as appropriate and response capabilities are documented in the letters of agreement maintained by Security.Evidence of agreements with participating local services is addressed in Appendix E; the Vermont Yankee Fire Protection Program; and the Annual Law Enforcement Letters of Agreement (Safeguards Information) maintained by Security.Permanently Defueled Emergency Plan Revision 0 Page 21 of 53 Entergy Vermont Yankee 8.2.3.2.Federal Government SuDDort Resources of federal agencies appropriate to an emergency condition are made available in accordance with the National Response Framework.

This plan and the resources behind it are activated through the plant notification of the NRC.8.2.3.3. Additional Support Dependent upon the emergency condition and response needs, the VY ERO can be augmented by manpower and equipment support from the remainder of the Entergy Nuclear organization.

This support capability is outlined in the Corporate Support procedure referenced in Appendix E.8.2.4. Recovery Organization The emergency measures presented in this plan are actions designated to mitigate the consequences of the accident in a manner that affords the maximum protection to plant personnel.

Planning for the recovery mode of operations involves the development of general principles and an organizational capability that can be adapted to any emergency situation.

The organizations described in Section 8.1 and 8.2 provides the foundation for such a recovery organization.

The Emergency Director directs the recovery organization.

The organization relies on plant staff and/or resources to restore the plant to normal conditions.

The expertise provided through the support plans is available to aid with the necessary corrective actions required to control and/or restore normal plant status. The following is a brief summary of the recovery organization's responsibilities:

1. Maintain comprehensive radiological surveillance of the plant to assure continuous control and recognition of problems;2. Control access to the area and exposure to workers;3. Decontaminate affected areas and/or equipment;

4. Conduct clean-up and restoration activities;

5. Isolate and repair damaged systems;6. Document all proceedings of the accident and review the effectiveness of the emergency organization in reducing public hazard and/or plant damage.When plant conditions allow a transition from the emergency phase to the recovery phase, the Emergency Director conducts a plant emergency management meeting to discuss the recovery organization.

The actions taken by this organization concerning termination of the Permanently Defueled Emergency Plan Revision 0 Page 22 of 53 Entergy Vermont Yankee emergency proceeds in accordance with a recovery plan developed specifically for the accident conditions.

8.3. Coordination

with State Government Authorities Section 7.0 describes the communications network between VY and the State of Vermont as a means of promptly notifying appropriate authorities under accident conditions.

The Shift Manager initiates notification of Vermont authorities, providing them with applicable information utilizing an established message format that describes the accident status. The Emergency Director, or designee, issues periodic reports to State of Vermont authorities.

Permanently Defueled Emergency Plan Revision 0 Page 23 of 53 Entergy Vermont Yankee Shift Manager /Emergency Director F~ _T Security NCO Fire RP Force Brigade Technician Emergency Response Organization Technical Radiation Coordinator Protection Coordinator r ---------------------r ----------------------T Federal Agencies State/Local Agencies i Local Services Figure 8.1 Normal On-Shift and Emergency Response Organization Permanently Defueled Emergency Plan Revision 0 Page 24 of 53 Entergy Vermont Yankee Table 8.1 Minimum On-Shift and ERO Staffing Requirements MAJOR FUNCTIONAL AREA MAJOR TASKS LOCATION VY EMERGENCY ON-SHIFT VY AUGMENTED STAFF POSITION, TITLE, OR CAPABILITY FOR EXPERTISE RESPONSE IN 2 HOURS Plant Operations and Plant Equipment Control Room Non-Certified Operator assessment of Operational Aspects / Fire Brigade Emergency Direction and Emergency Director Control Room Control Shift Manager Notification/Communication Notify Licensee, State local and Control Room Federal personnel and maintain communications Radiological Accident Onsite Dose Assessment and As Directed by the Radiation Protection 1 (may augment the ERO Assessment and Support of Monitoring Emergency Director Coordinator with Radiation Monitoring Operational Accident Personnel as deemed Assessment necessary)

In-Plant Surveys On-Scene Radiation Protection 1 Radiation Protection Technician Protective Actions (In-Plant)

a. Access Control b. HP Coverage for Repair, Corrective Actions, Search and Rescue, First Aid, and Firefighting

c. Personnel Monitoring

d. Dosimetry Plant Condition Evaluation, Technical Support As Directed by the Technical Coordinator 1 (may augment the ERO Repair, and Corrective Action Repair, Mitigation, and Corrective Emergency Director with technical support and Action emergency repair Develop strategies for search and personnel as deemed rescue and firefighting necessary)

Firefighting Firefighting On-Scene Fire Brigade Per the Fire Protection Plan Fire Team Leader Fire Fighting On- Scene Fire Brigade Per the Fire Rescue Operations/

First Aid Rescue and First Aid Protection Plan Site Access Control and Security, Firefighting, Per the Physical Security Personnel Per the Physical Accountability Communications, and Personnel Security Plan Security Plan Accountability Permanently Defueled Emergency Plan Revision 0 Page 25 of 53 Entergy Vermont Yankee

9.0 EMERGENCY

RESPONSE 9.1. Emergency Condition Recognition and Classification VY maintains the capability to assess, classify, and declare an emergency condition in accordance with plant procedures following identification of the appropriate emergency classification level.Section 5.0 presents the emergency classification system used for categorizing the wide spectrum of possible emergency conditions into one of two emergency classes. The process of condition recognition, immediate response to correct the condition, event classification, and initiation of the appropriate emergency implementing procedures are critical responsibilities of the Shift Manager and the on-shift crew.Site procedures contain the listing of conditions that represents each of the two emergency categories and the detailed EALs that allow the Shift Manager to determine the emergency classification.

Once the emergency is classified, the applicable emergency implementing procedure is initiated, the ERO is activated and the notification of offsite authorities is initiated.

The activation of the ERO brings to the assistance of the on-shift personnel the various support elements described in this plan. Specific support elements are implemented as detailed in the emergency implementing procedures.

See Appendix E for a listing of these procedures.

9.2. Activation

of the Emergency Response Organization Classification of an accident condition requires that the plant staff recognize that pre-established EALs associated with an emergency condition, as defined in Appendix A, have been reached or exceeded.

Depending upon the specific action levels attained, the Shift Manager declares one of the following:

Unusual Event or Alert. The Shift Manager activates the ERO if plant conditions reach predetermined EALs.9.2.1. Unusual Event Response Appendix A defines the conditions that require the declaration of an Unusual Event. An Unusual Event does not activate the ERO, but may require augmentation of on-shift resources to address the event. Offsite emergency organizations are notified for informational purposes, and aid from offsite fire, medical, and security organizations may be required depending on the nature of the event.The response required as a result of this declaration of a Unusual Event varies according to the specified event, but a general summary of actions taken is described below: 1. The emergency condition is recognized and classified by the Shift Manager who instructs Control Room personnel to announce the emergency classification over the plant page system;Permanently Defueled Emergency Plan Revision 0 Page 26 of 53 Entergy Vermont Yankee

2. The on-duty and selected plant personnel respond as directed by the Shift Manager and assume assigned functions;

3. Control Room personnel notify the Vermont State authorities;

4. The NRC is notified;5. Other support is requested as necessary;

6. The Emergency Call-in Method is implemented as shown in the notification plan (Figure 9.1);7. Additional personnel report to the plant as requested by the Shift Manager;8. The Shift Manager/Emergency Director directs the activities of emergency response personnel;

9. If necessary, appropriate emergency medical, fire department, or law enforcement agencies are notified and requested to respond;10. The public information representative is notified and handles public information associated with the event; and 11. The Shift Manager/Emergency Director terminates the Unusual Event status and closes out the event with a verbal summary to offsite authorities or escalates to higher level emergency classification.

The Unusual Event status will be maintained until an escalation in emergency class occurs or the event is terminated.

Offsite authorities will be informed of the change in the emergency status and the necessary documentation will be completed as specified in site procedures.

9.2.2. Alert

Response An Alert requires actions to assure that sufficient emergency response personnel are mobilized to respond to the accident conditions at the site. Notification is made to State officials and follow-up information is provided as needed to offsite emergency organizations.

In an Alert, the steps listed in the Unusual Event Response section (except for the termination process) and the following are performed:

1. ERO report to the Emergency Director;2. The Emergency Director/Shift Manager directs the evacuation of all visitors and unnecessary contractors from the plant;Permanently Defueled Emergency Plan Revision 0 Page 27 of 53 Entergy Vermont Yankee

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

4. The Emergency Director assumes total responsibility for overall emergency response actions and recovery;5. The Emergency Director reaches agreement with offsite authorities concerning de-escalation or termination of the event, and closes out the event by verbal summary to offsite authorities.

If an event is a reportable occurrence, a written summary is issued to these authorities in an appropriate time frame through distribution by the Emergency Director.The Alert status shall be maintained until termination of the event or de-escalation in emergency class occurs. The plant may enter recovery operation without de-escalating from a declared Alert. Off-site authorities will be informed of the change in the emergency status and the necessary documentation shall be completed as specified in site procedures.

9.3. Emergency

Termination Criteria An extensive review of plant parameters including SFP parameters and process and radiation monitoring systems, in conjunction with the pre-established EALs is required to terminate an emergency.

When plant conditions allow de-escalation in the emergency class, the Emergency Director directs the emergency response organization to perform certain response actions prior to implementing any change. These actions include: 1. Notification of all plant emergency management personnel of the pending change;2. Notification of offsite authorities of the pending change;3. Notification of corporate support services of the pending change;4. Coordination of media releases concerning the transition; and 5. Announcement of the transition over the plant page system.Termination of an emergency status is the responsibility of the Emergency Director.

The decision will be based on the following considerations:

1. Conditions no longer meet an EAL and it appears unlikely that conditions will deteriorate; Permanently Defueled Emergency Plan Revision 0 Page 28 of 53 Entergy Vermont Yankee

2. Plant releases of radioactive materials to the environment are under control (within Technical Specifications);

3. In-Plant radiation levels are stable or decreasing, and are acceptable given plant conditions;

4. Operability and integrity of power supplies, electrical equipment and plant instrumentation including radiation monitoring equipment is acceptable;

5. All required notifications have been made;6. Radiological and plant conditions permit resumption of normal occupational exposure limits to continue mitigation/repair activities.

Permanently Defueled Emergency Plan Revision 0 Page 29 of 53 Entergy Vermont Yankee SHIFT MANAGER Classify incident and notify: InForm/NAS VERMONT Notify State Authorities I S NRC Gai-tronics PLANT SECURITY 3 ERO notification system PLANT EMERGENCY RESPONSE ORGANIZATION Respond as assigned 2 Figure 9.1 Notification Plan Permanently Defueled Emergency Plan Revision 0 Page 30 of 53 Entergy Vermont Yankee 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES 10.1. Radiological Assessment 10.1.1. Initial Radiological Dose Projection VY has developed a method to quickly determine the projected radiological conditions at the Site boundary.

During the initial stages of an emergency, the Shift Manager or designated individual is responsible to perform the initial evaluation of radiological conditions.

The initial evaluation is accomplished in accordance with site procedures.

10.2. Radiological Exposure Control During a plant emergency, abnormally high levels of radiation and/or radioactivity may be encountered by plant personnel.

All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, or corrective or assessment actions within applicable limits specified in 10 CFR Part 20.Table 10.1 specifies the guidelines on emergency dose limits for personnel providing emergency response duties consistent with Table 2-2, "Response Worker Guidelines," provided in the EPA PAG Manual. The Shift Manager/Emergency Director has the responsibility to authorize emergency dose commitments in excess of 10 CFR Part 20 limits. This authorization is coordinated with the assistance of the Radiation Protection Coordinator.

Exposure to individuals providing emergency functions will be consistent with the limits specified in Table 10.1 with every attempt made to keep exposures As Low As Reasonably Achievable (ALARA).The Radiation Protection Coordinator is responsible for developing emergency radiological protection programs for ERO and augmented personnel.

Emergency kits are provided with self-reading dosimeters.

Each member reporting to the site will be provided a Dosimeter of Legal Record (DLR). Dose records will be maintained based upon the results of the self-reading dosimeters.

This information is cross-referenced with the DLR data. The capability exists for the emergency processing of DLRs on a 24-hour per day basis.Emergency workers are instructed to read self-reading dosimeters frequently, and DLRs may be processed with increased periodicity.

10.3. Protective Measures 10.3.1. Site Personnel Accountability The goal of the personnel accountability process is to account for personnel at an Alert declaration.

Accountability for an Unusual Event is at the discretion of the Emergency Director.

Plant procedures require Security personnel to maintain a list of personnel entering or leaving the site during a site evacuation.

The Emergency Director, Technical Coordinator and Radiation Protection Coordinator are responsible for accounting for their Permanently Defueled Emergency Plan Revision 0 Page 31 of 53 Entergy Vermont Yankee staff. An organizational sign-in method which enhances this reporting process is maintained.

All reports are provided to the Emergency Director, who initiates search and rescue actions for any missing personnel.

Plant security provides assistance for this accountability effort and aids in the control of personnel during extended emergency operations.

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

10.3.2. Site Egress Control Methods All visitors and unnecessary contractors are evacuated from the plant upon an Alert declaration.

All personnel are monitored for radioactive contamination prior to leaving the site. Portable radiation survey meters are available to frisk personnel for suspected contamination.

If a Code Red Security event has been declared, evacuation and accountability may put personnel at risk. In these security situations, evacuation and accountability may be suspended until directed by Security.Plant evacuees are advised of evacuation procedures prior to being released.10.3.3. Decontamination Capability VY maintains an in-plant decontamination facility.

Waste generated through the use of this system is collected and processed by the plant liquid radwaste system. Survey instrumentation for personnel "frisking" and sensitive body burden monitoring equipment are available in various plant locations.

Decontamination is performed under the direction of the Radiation Protection Coordinator.

10.3.4. Use of Onsite Protective Equipment and Supplies The plant supplies of personnel radiation protection equipment and gear are utilized to support the emergency response effort. Equipment such as respiratory protection gear and protective clothing is assigned to emergency response organization members and plant response personnel in accordance with established plant radiation protection criteria.10.3.5. Fire Fighting Strategies have been developed for firefighting and fire protection in specific critical areas of the plant. The Fire Protection Program describes the fire protection organization and individual responsibilities.

Permanently Defueled Emergency Plan Revision 0 Page 32 of 53 Entergy Vermont Yankee 10.4. Aid to Affected Personnel 10.4.1.Medical Treatment In-plant medical supplies are provided on-site. Initial on-site medical treatment is provided by on-site personnel.

Arrangements exist with Brattleboro Memorial Hospital as indicated in Section 8.2.3.1. The agreement includes a commitment by the hospital to accept and treat plant personnel with routine industrial injuries as well as injuries complicated by radioactive contamination or radiation exposure.

The hospital maintains the capability and facilities to provide decontamination.

The hospital participates in medical emergency drills.10.4.2.Medical Transportation Arrangements exist with Rescue, Inc., to provide 24-hour ambulance service for emergency transportation of plant personnel for offsite treatment.

The ambulance service is capable of radio communications with the hospital while en route with a patient. Normal telecommunication channels are used in notifying the ambulance service dispatch center.Rescue, Inc. personnel are provided with specific training by VY on the health physics considerations associated with radioactively contaminated personnel and site access control measures.10.5. Protective Actions for Onsite Personnel A range of protective actions to protect onsite personnel is provided to ensure the continued ability to perform the functions of the emergency plan.Permanently Defueled Emergency Plan Revision 0 Page 33 of 53 Entergy Vermont Yankee TABLE 10.1 EMERGENCY DOSE LIMITS (refer to Note 1 )Guideline Activity ] Condition All reasonably achievable 5 rem All occupational exposures actions have been taken to minimize dose.Exceeding 5 rem unavoidable 10 rem(a) Protecting Valuable Property tand allappropriateduce dose.10 rem ~~~~~necessary for public welfare taetordcds.

Monitoring available to project or measure dose.Exceeding 5 rem unavoidable 25 rem(b) Lifesaving or Protection of tand allappropriateduce dose.Large Population Monitoring available to project or measure dose.NOTES: 1. Reference for this table is Table 2-2 of the EPA PAG Manual.(a) For potential doses > 5 rem, medical monitoring programs should be considered.(b) In the case of a very large incident, consider the need to raise the property and lifesaving Response Worker Guideline to prevent further loss.Permanently Defueled Emergency Plan Revision 0 Page 34 of 53 Entergy Vermont Yankee 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 11.1. Emergency Notification The Shift Manager is responsible for the notification of an emergency declaration to the State of Vermont. Notification is made within 60 minutes of emergency declaration or change in classification.

Due to the slow rate of the postulated event scenarios in the accident analysis and the absence of immediate actions necessary to protect the public health and safety, the notification time of 60 minutes is appropriate.

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

The Department of Public Health of Vermont may request the following information from VY: 1. Date and time of the incident;2. Emergency classification;

3. Status of the facility;4. Whether a release has occurred, is occurring, or is anticipated to occur;5. Actual or projected dose rates at the Site boundary;Follow-up reports are provided as additional information describing the emergency situation becomes available and on an as-needed basis until such time that the emergency condition has been terminated.

11.2. Public Information Any emergency generates a continuous and intensive demand for up-to-date information.

As part of its normal corporate structure, Entergy maintains a corporate public affairs office.Upon declaration of an Unusual Event or Alert, information is disseminated to the public and briefings will be held with pertinent media organizations in accordance with Entergy corporate communication protocols.

Additionally, Federal, State and local emergency response organizations maintain the capability to disseminate appropriate information regarding an emergency at VY.VY maintains a public inquiry phone for media and public use. During an emergency, a pre-recorded message will provide up-to-date status reports regarding the situation.

Permanently Defueled Emergency Plan Revision 0 Page 35 of 53 Entergy Vermont Yankee 12.0 MAINTAINING EMERGENCY PREPAREDNESS 12.1. Drills and Exercises An exercise tests the execution of the overall plant emergency preparedness and the integration of this preparedness.

A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular response function.Emergency exercises and drills are conducted to test and evaluate the adequacy of emergency facilities, equipment, procedures, communication channels, actions of emergency response personnel, and coordination between offsite organizations and the facility.A summary of exercises and drills and associated elements is outlined below.12.1.1. Radiation Emergency Exercises and Drills Biennial exercises shall be conducted to test the timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel are familiar with their duties. VY offers the following organizations the opportunity to participate to the extent assistance would be expected during an emergency declaration; however, participation is not required: 1. State of Vermont 2. Brattleboro Memorial Hospital 3. Brattleboro Fire Department

4. Law Enforcement

5. Rescue, Inc. Ambulance Service At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between biennial exercises.

Communication checks with offsite agencies, fire drills, medical drills, radiological monitoring drills and health physics drills are performed as indicated in the following sections.12.1.2. Communication Tests To ensure that emergency communications systems described in Section 7.0 of this plan are operable, communications tests are conducted as outlined below.Permanently Defueled Emergency Plan Revision 0 Page 36 of 53 Entergy Vermont Yankee

1. Communication channels with the state government of Vermont, is tested monthly. These communications tests will include the aspect of understanding the content of messages.2. The ENS is tested as described in subsection 7.6 of this plan.3. The following communication systems, as detailed in Section 7.0 of this plan, are used on a frequent basis, therefore periodic testing of these systems is not necessary:

• Mobile UHF Radio System" Plant Intercom System (Gai-Tronics)" Commercial Telephone System To ensure the reliability of the plant's call-in procedure, a semi-annual functional test of the ERO notification system is performed to test system performance.

This can be performed separately or during the Augmentation Capability Drill described in Section 12.1.3.12.1.3. Augmentation Capability Drills Semi-annual, off hours, unannounced, communications drill, utilizing both the ERO notification system and commercial telephone, to estimate emergency personnel response times. No actual travel is required.

Participants provide an estimation of the time it would take to report to their designated ERO position.

This drill shall serve to demonstrate the capability to augment the on shift staff after declaration of an emergency.

12.1.4. Fire Drills To test and evaluate the response and training of the plant's fire brigade, fire drills are conducted in accordance with the Vermont Yankee Fire Protection Program.To demonstrate the coordination between the plant's fire brigade and the Vernon Fire Department, the fire department is annually offered the opportunity to participate in an onsite fire drill.12.1.5. Medical Drills To evaluate the training of the facility's medical response and offsite medical response (ambulance and hospital), a medical drill is conducted annually with a simulated contaminated injured individual.

This drill can be performed as part of an Emergency Plan drill or exercise.12.1.6. Radiological Monitoring Drills Plant environs and radiological monitoring drills are conducted annually.

These drills include monitoring of accessible areas within the plant and include collection and analysis Permanently Defueled Emergency Plan Revision 0 Page 37 of 53 Entergy Vermont Yankee of airborne sample media, communications, and record keeping performed by members of the emergency team. This drill can be performed as part of an Emergency Plan drill or exercise.12.1.7. Health Physics Drills Health Physics drills are conducted semi-annually involving response to, and analysis of, simulated elevated in-plant airborne and liquid samples and direct radiation measurements in the environment.

A drill can be performed as part of an Emergency Plan drill or exercise.12.1.8. Security Drills The purpose of the security drill is to maintain key skills, specifically the site-specific team skills necessary to mitigate security-based events. Security drills are conducted in accordance with the Vermont Yankee Physical Security Plan.12.1.9. Scenarios An Exercise/Drill Coordinator is responsible for an Emergency Plan drill or exercise.

The Exercise/Drill Coordinator's responsibilities include developing the exercise/drill scenario, the accident time sequence, and the selection and training of the Controllers required to evaluate the effectiveness of the VY Emergency Preparedness Program.A scenario is prepared by the Scenario Development Group for each exercise/drill to be conducted.

The scenario varies year to year and is approved by Vermont Yankee Management.

Within an eight-year period, the scenario content is varied to test all the major elements of the Emergency Preparedness Program.The contents of the scenario include, but are not limited to, the following:

1. Basic objective(s);

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

3. Simulation lists;4. Time schedule of real and simulated initiating events;5. A narrative summary describing the conduct of the drill or exercise to include such items as simulated casualties, search and rescue of personnel, deployment of radiological monitoring teams, and public information affairs;and 6. List of Controllers.

Permanently Defueled Emergency Plan Revision 0 Page 38 of 53 Entergy Vermont Yankee The scenarios are designed to allow free play in exercising the decision-making process associated with such emergency response actions as exposure control, emergency classification and de-escalation, and the ERO and additional staff augmentation process.Security based scenarios to test and evaluate security response capabilities will be conducted in accordance with security drills and exercise procedures and may be conducted during Emergency Plan drills or exercises.

Starting times and pre-notification for exercises are coordinated with and agreed upon by all participating organizations.

12.1.10. Evaluation of Exercises To evaluate the performance of participating facility personnel and the adequacy of emergency facilities, equipment and procedures during an exercise, the Exercise Coordinator obtains qualified controllers which includes resources outside the facility to evaluate and critique the exercise.When feasible, personnel designated as controllers are assigned to an Emergency Plan area germane to their area of expertise.

Controllers are provided general instruction concerning their specific observation function.

Each controller is requested to observe the implementation of the emergency plan element assigned to him or her, and then to record and report observed inadequacies.

A critique is conducted at the conclusion of the exercise with facility personnel.

After the critique, the controllers submit a written evaluation to the Exercise Coordinator in which the exercise performance is evaluated against the objectives.

All comments and/or recommendations are documented.

Weaknesses and/or deficiencies identified in an exercise critique are processed in accordance with the site corrective actions program.12.1.11. Emergency Plan Audit The VY Emergency Plan is independently audited as part of the Vermont Yankee In-plant Audit Program. The audit is conducted as part of the Quality Assurance Program in accordance with 10 CFR 50.54(t).

All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.12.2. Training All non-essential plant personnel receive annual instruction, in accordance with"Emergency Plan Training," concerning their expected response action during an emergency.

Those members of the plant staff who have been assigned to the ERO receive annual training which includes, but is not limited to, the following:

Permanently Defueled Emergency Plan Revision 0 Page 39 of 53 Entergy Vermont Yankee

1. Familiarize individuals with Emergency Plan and implementing procedures, especially where emergency response tasks are not part of their normal duties;2. Define an individual's responsibilities associated with their designated function;3. Familiarize individuals in emergency exposure control measures and guidelines, particularly those associated with an individual's designated emergency functions; and 4. Provide sufficient technical insight to maintain emergency functions.

A portion of this training is provided by personnel's participation in drills or exercises.

During these drills and exercises, controllers check the performance of the personnel assigned, and provide critiques which could be incorporated in future training.

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

12.3. Review and Updating of Plan and Procedures The Emergency Plan is reviewed at least annually and the associated implementing procedures are reviewed at least biennially.

All recommendations for changes to the Emergency Plan or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q).

The Emergency Plan is submitted to VY's On-Site Safety Review Committee for approval.Written agreements with outside support organizations and government agencies are evaluated annually to determine if these agreements are still valid. If agreements are not valid, then they are renewed and updated. This agreement review is documented.

Revisions to the Emergency Plan are made in accordance with current regulations and guidelines.

Changes to the Emergency Plan are forwarded to organizations and individuals with a responsibility for implementation of the Plan.Telephone number listings associated with the emergency notification process are verified quarterly.

12.4. Maintenance and Inventory of Emergency Equipment and Supplies The emergency equipment maintained in the Control Room is contained in a checklist in Emergency Equipment Readiness Check.Designated personnel conduct a weekly test of certain emergency communications equipment.

At least quarterly in accordance with the emergency equipment inventory Permanently Defueled Emergency Plan Revision 0 Page 40 of 53 Entergy Vermont Yankee procedure, and subsequent to each usage, designated VY personnel are assigned to inventory and maintain the emergency kits and/or equipment.

Rotation of survey instruments normally used in the plant with instruments in the Emergency Kits assures that emergency equipment is calibrated and fully operable.

There are sufficient reserve instruments and equipment to replace those that are removed from emergency kits for calibration purposes.

Appendix B contains a list of emergency equipment by location.12.5. Responsibility for the Planning Effort The Senior Site Executive has overall responsibility for implementation of the Emergency Plan at VY. The Emergency Planning Manager is responsible for emergency planning and the interface with offsite authorities and organizations.

The duties of the Emergency Planning Manager include, but are not limited to, the following:

1. Revise and update the Emergency Plan;2. Maintain the Emergency Plan implementing procedures so that they are updated and current with the Emergency Plan;3. Schedule and ensure the conduct of emergency equipment inventories and calibration;

4. Represent the plant in offsite Emergency Plan interfaces;

5. Represent the plant in NRC emergency planning appraisals and audits;6. Interface with the Exercise Coordinator in preparing and coordinating Emergency Plan drills and exercise; and 7. Maintain drill and exercise documentation and coordinate implementation of corrective actions deemed necessary following drills and exercises.

Permanently Defueled Emergency Plan Revision 0 Page 41 of 53 Entergy Vermont Yankee APPENDIX A EMERGENCY CLASSIFICATION SYSTEM AND EMERGENCY ACTION LEVELS[NOTE: Reference AP 3125, Emergency Plan Classification and Action Level Scheme for the most current revision of the EAL Charts.]Permanently Defueled Emergency Plan Revision 0 Page 42 of 53 Entergy Vermont Yankee APPENDIX B EMERGENCY EQUIPMENT This Appendix contains a list of emergency equipment by location.

Backup equipment is available at the Radiation Protection control point. In addition, the resources referenced in subsections 6.2.5 and 10.2 of this Plan are at the disposal of Vermont Yankee in an emergency.

Permanently Defueled Emergency Plan Revision 0 Page 43 of 53 Entergy Vermont Yankee APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATION MAIN INNER CONTROL GATE EQUIPMENT ROOM HOUSE Respiratory Protection 9 Radiation Monitoring

°Dosimetry

°Sampling 0 Communications

• Dose Assessment 0 Area Maps 0 Emergency References Protective Clothing Decontamination Barrel Administrative Support 0 Status Boards o Stack Sampling , Sampling Cartridges o Portable Lead Shielding

_Emergency Centers &Emergency Room Keys Station Sampling Cartridges

_Environmental Station Keys _(A more detailed listing of emergency equipment is provided in EPOP-EQUIP-3506,"Emergency Equipment Readiness Check")Permanently Defueled Emergency Plan Revision 0 Page 44 of 53 Entergy Vermont Yankee APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY SLOCATION EQUIPMENT Provided by other non-affected Entergy nuclear sites, as needed Gamma Spectroscopy High Pressure Ion Chamber Mobile Processing DLR Unit Personnel

&Environmental

.DLR Permanently Defueled Emergency Plan Revision 0 Page 45 of 53 Entergy Vermont Yankee APPENDIX C ENVIRONMENTAL LABORATORY ANALYTICAL AND DOSIMETRY SERVICES Permanently Defueled Emergency Plan Revision 0 Page 46 of 53 Entergy Vermont Yankee APPENDIX C (Continued)

General In the event of a radiological emergency at Vermont Yankee, laboratory services (as described in 6.2.5) are available, on a 24-hour emergency call basis, to perform gamma isotopic analyses on samples taken by the plant's emergency monitoring teams. Portable gamma spectroscopy equipment can be deployed to the plant site to determine the presence and level of contamination in samples of various media in the event of an accidental release of radioactive material.Portable Emergency Analysis Equipment Portable analysis equipment with computerized spectral analysis capability may be deployed to assist in an emergency response.

A report of plant-related nuclide concentrations, standard deviation, and Minimum Detectable Concentration (MDC) is forwarded to assessment personnel.

Following a request from Vermont Yankee for assistance in assessing an emergency condition, laboratory personnel will be dispatched to a designated location within approximately four (4) to eight (8) hours. Upon arrival, laboratory personnel will determine the presence and level of contamination in samples of various media (air cartridges, air filters, vegetation, water).Emergency DLR Services The capability exists for the emergency processing of DLRs on a 24-hour per day basis.Emergency workers are instructed to read self-reading dosimeters frequently, and DLRs may be processed with increased periodicity.

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

The analytical methodology provides a whole body scan and identifies activity content of the lung, GI, and thyroid.A result report is generated for those plant-related nuclides found to be present at the 99%confidence level.Permanently Defueled Emergency Plan Revision 0 Page 47 of 53 Entergy Vermont Yankee APPENDIX D LETTERS OF AGREEMENT Permanently Defueled Emergency Plan Revision 0 Page 48 of 53 Entergy Vermont Yankee APPENDIX D (Continued)

Letters of agreement in effect between Vermont Yankee and the offsite authorities are maintained in the Emergency Planning Department files. Entergy Operations, Inc.maintains agreements and/or contracts with the following organizations in support of Vermont Yankee Emergency Response.Letters of Agreement have been ascertained with offsite groups to provide on-site aid in the event of an emergency situation at Vermont Yankee.Ambulance Service: Twenty-four (24) hour ambulance service is provided by Rescue Inc.Mutual aid backup from other ambulance services provides for additional emergency medical services, ambulances and EMS personnel.

Onsite procedures contain instructions that cover the call for assistance and the handling of the ambulance service personnel.

Radio communication exists between the ambulance and local hospitals.

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

Brattleboro Memorial Hospital has agreed to accept patients from Vermont Yankee who have been injured, contaminated or irradiated.

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

Law Enforcement:

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

Permanently Defueled Emergency Plan Revision 0 Page 49 of 53 Entergy Vermont Yankee APPENDIX D (Continued)

Letters of Agreement 1. State of Vermont 2. Brattleboro Memorial Hospital 3. Rescue, Inc. Ambulance Service 4. Vernon Fire Department

5. Brattleboro Fire Department

6. Town of Vernon 7. Department of Energy 8. DOE -REAC/TS 9. Law Enforcement

• All letters of agreement from Local Law Enforcement Authorities as required by the Physical Security Plan are classified as Safeguards Information and as such are maintained by Security.Permanently Defueled Emergency Plan Revision 0 Page 50 of 53 Entergy Vermont Yankee APPENDIX E INDEX OF EMERGENCY PLAN IMPLEMENTING PROCEDURES AND SUPPORT PLANS Permanently Defueled Emergency Plan Revision 0 Page 51 of 53 Entergy Vermont Yankee APPENDIX E (Continued)

EMERGENCY PLAN IMPLEMENTING PROCEDURES AP 3125 Emergency Plan Classification and Action Level Scheme EPOP-COMM-3504 Emergency Communications EPOP-EQUIP-3506 Emergency Equipment Readiness Check OP 3507 Emergency Radiation Exposure Control OP 3508 Onsite Medical Emergency Procedure OP 3509 Environmental Sample Collection during an Emergency OP 3510 Site Boundary Monitoring AP 3532 Emergency Preparedness Organization OP 3536 In-plant Air Sample Analysis with Abnormal Conditions EPOP-CR-3540 Control Room Actions During an Emergency OP 3547 Security Actions During an Emergency OP 3548 Emergency Termination and Recovery AP 3554 Emergency Plan Teams AP 3712 Emergency Plan Training AP-1 0049 Equipment Important to Emergency Response EPAP-INFORM-10076 InForm Notification System EN-EP-303, Severe Weather Recovery EN-EP-305, Emergency Planning 10 CFR 50.54(q) Review Program EN-EP-306, Drills and Exercises EN-EP-308, Emergency Planning Critiques EN-EP-309, Fatigue Management for Hurricane Response Activities EN-EP-310, Emergency Response Organization Notification System EN-EP-401, Public Use of Emergency Preparedness Owner Controlled Area EN-EP-606, Pandemic Flu Response Permanently Defueled Emergency Plan Revision 0 Page 52 of 53 Entergy Vermont Yankee APPENDIX E (Continued)

II. SUPPORT PLANS*The Vermont Yankee Severe Accident Management Program (PP 7019)The Vermont Yankee Physical Security Plan Vermont Yankee Fire Protection and Safe Shutdown (SEP-FP-VTY-003)

NRC Incident Response Plan (NUREG-0728)

National Response Framework (January 2008)Procedure for Admission and Management of Radioactively Contaminated Patients at Brattleboro Memorial Hospital* This list does not reference any of the emergency plan arrangements specified in Appendices D and E of this plan.Permanently Defueled Emergency Plan Revision 0 Page 53 of 53 Entergy Vermont Yankee BVY 14-033 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Permanently Defueled Emergency Action Level Bases Document Vermont Yankee Nuclear Power Station Permanently Defueled Emergency Action Level Technical Bases Revision 0 Prepared by: Planner, Emergency Planning Date Approved by: Manager, Emergency Planning Date Approved by: Manager, Operations Date Page 1 of 51 Table of Contents Section Paae 1.0 PURPO SE ...........................................................................................................................

4 2.0 DISCUSSIO N .......................................................................................................................

4 2.1 Perm anently Defueled Station .....................................................................................

4 2.2 Independent Spent Fuel Storage Installation

...............................................................

4 3.0 KEY TERM INO LO GY USED .........................................................................................

5 3.1 Em ergency Classification Level .....................................................................................

6 3.1 Initiating Condition

......................................................................................................

6 3.1 Em ergency Action Level ...............................................................................................

7 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS

.......................................

7 4.1 General Considerations

................................................................................................

7 4.2 Classification M ethodology

...........................................................................................

8 4.3 Classification of M ultiple Events and Conditions

...........................................................

8 4.4 Classification of Imminent Conditions

.........................................

8 4.5 Emergency Classification Level Upgrading and Downgrading

.......................................

8 4.6 Classification of Short-Lived Events .............................................................................

9 4.7 Classification of Transient Conditions

..........................................................................

9 4.8 After-the-Fact Discovery of an Emergency Event or Condition

..................................

109 4.9 Retraction of an Em ergency Declaration

...................................................................

10 5.0 REFERENC ES ...................................................................................................................

10 5.1 Developm ental ................................................................................................................

10 5.2 Im plem enting ..................................................................................................................

10 5.3 Com m itm ents ..................................................................................................................

10 6.0 DEFINITIO NS & AC RO NYM S .......................................................................................

11 7.0 VYNPS-TO-NEI 99-01 EAL CROSS REFERENCE

.......................................................

15 8.0 ATTAC HM ENTS ................................................................................................................

15 8.1 Attachm ent 1, Recognition Category PD EAL Bases ..................................................

16 Abnorm al Rad Levels/Rad Effluent .................................................................................

18 PD-AU1.1 Unusual Event ...........................................................................................

18 PD-AU1.2 Unusual Event ...........................................................................................

20 PD-AA1.1 Alert ................................................................................................................

22 Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 2 of 51 PD-AA1.2 Alert ................................................................................................................

24 PD-AA1.3 Alert ................................................................................................................

26 PD-AA1.4 Alert ................................................................................................................

28 PD-AU2.1 Unusual Event ...........................................................................................

30 PD-AU2.2 Unusual Event ...........................................................................................

32 PD-AA2.1 Alert ................................................................................................................

34 PD-AA2.2 Alert ................................................................................................................

35 Hazards and Other Conditions Affecting Plant Safety .....................................................

37 PD-HU1.1 Unusual Event ............................................................................................

37 PD-HU1.2 Unusual Event ............................................................................................

38 PD-HU1.3 Unusual Event ............................................................................................

39 PD-HAI.1 Alert ................................................................................................................

40 PD-HAI.2 Alert ................................................................................................................

42 PD-HU2.1 Unusual Event ............................................................................................

44 PD-HU3.1 Unusual Event ............................................................................................

46 PD-HA3.1 Alert ................................................................................................................

47 System Malfunction

..............................................................................................................

48 PD-SU1.1 Unusual Event ...........................................................................................

48 8.2 Attachment 2, Recognition Category E EAL Basis .....................................................

49 Independent Spent Fuel Storage Installation

...................................................................

51 E-HU1.1 Unusual Event ................................................................................................

51 Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 3 of 51

1.0 PURPOSE

This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Vermont Yankee Nuclear Power Station (VY) and the associated Technical Bases using the EAL development methodology found in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (NEI 99-01, Rev. 6). As a Permanently Defueled Station, VY will use the Recognition Category "PD" (Permanently Defueled) providing a stand-alone set of ICs/EALS for a permanently defueled nuclear power plant to consider for use in developing a site-specific emergency classification scheme. (Permanently defueled station ICs and EALs are addressed in Appendix C of NEI 99-01, Rev. 6.) All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q).This document should be used to facilitate review of the VY EALs, provide historical documentation for future reference and serve as a resource for training.

Decision-makers responsible for implementation of AP-3125, Emergency Plan Classification and Action Level Scheme, may use this document as a technical reference in support of EAL interpretation.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 60 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

2.0 DISCUSSION

2.1 Permanently

Defueled Station NEI 99-01 provides guidance for an emergency classification scheme applicable to a permanently defueled station. This is a station that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations and will store the spent fuel onsite for an extended period of time. The emergency classification levels applicable to this type of station are consistent with the requirements of 10 CFR Part 50 and NUREG-0654/FEMA-REP-1,"Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1" (NUREG-0654).

In order to relax the emergency plan requirements applicable to an operating station, the owner of a permanently defueled station must demonstrate that no credible event can result in a significant radiological release beyond the site boundary.

It is expected that this verification will confirm that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency.

Therefore, the generic Initiating Conditions (ICs) and Emergency Action Levels (EALs)applicable to a permanently defueled station may result in either a Notification of Unusual Event (Unusual Event) or Alert classification.

2.2 Independent

Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6 is applicable to licensees electing to use their 10 CFR Part 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone Independent Spent Fuel Storage Installation (ISFSI). The emergency classification levels applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The initiating Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 4 of 51 conditions germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567) are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1 140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees" (NUREG-1 140).NUREG-1 140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety. This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 rem Effective Dose Equivalent.

Regarding the above information, the expectations for an offsite response to an Alert classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an Unusual Event in a 10 CFR 50.47 emergency plan (e.g., to provide assistance, if requested).

Also, the licensee's Emergency Response Organization (ERO) required for 10 CFR 72.32 emergency plan is different than that prescribed for a 10 CFR 50.47 emergency plan (e.g., no emergency technical support function).

3.0 KEY TERMINOLOGY USED There are several key terms that appear throughout the NEI 99-01, Rev. 6 methodology.

These terms are introduced in this section to support understanding of subsequent material.

As an aid to the reader, the following table is provided as an overview to illustrate the relationship of the terms to each other.Emergency Classification Level Unusual Event Alert Initiating Condition Initiating Condition Permanently Defueled Emergency Action Permanently Defueled Emergency Action Level 1 Level 1" Notes 0 Notes" Basis

• Basis 1 When Making an emergency classification, the Shift Manager/Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition.

This includes the PD EALs, Notes and the Basis information.

Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 5 of 51

3.1 Emergency

Classification Level One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:* Unusual Event" Alert 3.1.1 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Purpose: The purpose of this classification is to assure that the first step in future response has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of unusual event information and decision-making.3.1.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.Purpose: The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required, and provide offsite authorities current information on plant status and parameters.

3.2 Initiating

Condition An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Discussion:

An Initiating Condition (IC) describes an event or condition, the severity or consequences of which meets the definition of an emergency classification level. An IC can be expressed as a continuous, measurable parameter (e.g., radiation monitor readings) or an event (e.g., an earthquake).

Appendix 1 of NUREG-0654 does not contain example EALs for each ECL, but rather Initiating Conditions (i.e., plant conditions that indicate that a radiological emergency, or events that could lead to a radiological emergency, has occurred).

NUREG-0654 states that the Initiating Conditions form the basis for establishment by a licensee of the specific plant instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification.

Thus, it is the specific instrument readings that would be the EALs.Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 6 of 51

3.3 Emergency

Action Level A pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the plant in a given emergency classification level.Discussion:

EAL statements may utilize a variety of criteria including instrument readings and status indications; observable events; results of calculations and analyses; entry into particular procedures; and the occurrence of natural phenomena.

4.0 GUIDANCE

ON MAKING EMERGENCY CLASSIFICATIONS

4.1 General

Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an IC. This includes the EAL plus Notes and the informing Basis information.

All emergency classification assessments should be based upon valid indications, reports or conditions.

A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy.

For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

The validation of indications should be completed in a manner that supports timely emergency declaration.

For I(s and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), the Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component.

In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected.

Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72.The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., gaseous and liquid effluent sampling, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis.

In these cases, the declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available).

Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 7 of 51 While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary.

The NEI 99-01 scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

4.2 Classification

Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded.

The evaluation of an EAL(s) must be consistent with the Notes. If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with plant procedures.

When assessing an EAL that specifies a time duration for the off-normal condition, the EAL time duration runs concurrently with the emergency notification time duration.4.3 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared.

For example:* If an Unusual Event EAL and an Alert EAL are met, an Alert should be declared.There is no "additive" effect from multiple EALs meeting the same ECL. For example:* If two Alert EALs are met, an Alert should be declared.Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, "Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events." 4.4 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT).

If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification level since it provides additional time for implementation of protective measures.4.5 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 8 of 51 is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated.

The following approach to downgrading or terminating an ECL is recommended:

ECL Action When Condition No Longer Exists Unusual Event Terminate the emergency in accordance with plant procedures Alert Downgrade or terminate the emergency in accordance with plant procedures.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02.4.6 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance.

By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed.

If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration.

Examples of such events would be an earthquake or an explosion.

4.7 Classification

of Transient Conditions Many of the ICs and/or EALs contained in this document employ time-based criteria.

These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted.

In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes).

The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response -In instances where an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration

-If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required.It is important to stress that the emergency classification assessment period is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event; emergency classification assessments must be deliberate and timely, with no undue delays.Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 9 of 51 4.8 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition.

This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery.

This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022, "Event Report Guidelines 10 CFR 50.72 and 50.73," is applicable.

Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 within one hour of the discovery of the undeclared event or condition.

The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

4.9 Retraction

of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022.

5.0 REFERENCES

5.1 Developmental

5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing E vents, February 2007 5.1.4 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 5.1.5 1- CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 5.1.7 10 CFR 72.32, Emergency Plan 5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.9 10 CFR 50.47, Emergency Plans 5.1.10 NUREG-1 140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees 5.2 Implementing 5.2.1 AP-3125 Emergency Plan Classification and Action Level Scheme 5.2.2 EAL Comparison Matrix 5.2.3 EAL Classification Matrix 5.3 Commitments Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 10 of 51 None 6.0 ACRONYMS & DEFINITIONS Acronyms CDE .................................................................................................

Com m itted Dose Equivalent CFR .................................................................................................

Code of Federal Regulations EAL ........................................................................................................

Em ergency Action Level ECL .............................................................................................

Em ergency Classification Level EO P .........................................................................................

Em ergency O perating Procedure EPA ..........................................................................................

Environm ental Protection Agency FAA ........................................................................................................

Federal Aviation Agency FBI ..............................................................................................

Federal Bureau of Investigation FEM A ..........................................................................

Federal Em ergency M anagem ent Agency FSAR ................................................................................................

Final Safety Analysis Report ISFSI .......................................................................

Independent Spent Fuel Storage Installation IC ....................................................................................................................

Initiating Condition M PF ......................................................................................................

M axim um Probable Flood m rem ............................................................................................

m illi-Roentgen Equivalent M an M SL .....................................................................................................................

M ean Sea Level NEI .........................................................................................................

Nuclear Energy Institute NO RAD ..............................................................

North Am erican Aerospace Defense Com m and NPP ..............................................................................................................

Nuclear Power Plant NRC ...........................................................................................

Nuclear Regulatory Com m ission O DCM/O DAM .....................................................

Off-site Dose Calculation (Assessm ent) M anual O RO ............................................................................................

Off-site Response O rganization PAG ........................................................................................................

Protective Action G uide rem .......................................................................................................

Roentgen Equivalent Man SM ..........................................................................................................................

Shift M anager TEDE ..........................................................................................

Total Effective Dose Equivalent Definitions The following definitions are taken from Title 10, Code of Federal Regulations, and related guidance documents.

Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 11 of 51 threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.The following are key terms necessary for overall understanding the NEI 99-01 emergency classification scheme.Emergency Action Level (EAL): A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given emergency classification level.Emergency Classification Level (ECL): One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The ECLs, in ascending order of severity, are: " Unusual Event* Alert Emergency Action Levels A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given emergency classification level.Initiating Condition (IC)An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Selected terms used in Initiating Condition and Emergency Action Level statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document.

The definitions of these terms are provided below.CONFINEMENT BOUNDARY The barrier(s) between areas containing radioactive substances and the environment.

EXPLOSION A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or over pressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 12 of 51 automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.FIRE Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.HOSTAGE A person(s) held as leverage against the station to ensure that demands will be met by the station.HOSTILE ACTION An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities, (i.e., this may include violent acts between individuals in the owner controlled area).HOSTILE FORCE One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

IMMINENT The trajectory of events or conditions is such than an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.NORMAL LEVELS As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.OWNER CONTROLLED AREA The area outside the Protected Area, owned by Entergy.Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 13 of 51 PROJECTILE An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA An area which normally encompasses all controlled areas within the security protected area fence as depicted in Drawing 5920-13013, Protected Area Fence.SECURITY CONDITION Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.UNPLANNED A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.VISIBLE DAMAGE Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 14 of 51 7.0 VYNPS-TO-NEI 99-01 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a Vermont Yankee EAL within the NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding the development of the Vermont Yankee EALs based on the NEI guidance can be found in the EAL Comparison Matrix (Reference 5.2.2).VY Permanently Defueled IC/EALs NEI 99-01, Rev. 6, Appendix C -Permanently Defueled Station ICs/EALs PD-AU1 PD-AU1 PD-AA1 PD-AA1 PD-AU2 PD-AU2 PD-AA2 PD-AA2 PD-HU1 PD-HU1 PD-HA1 PD-HA1 PD-HU2 PD-HU2 PD-HU3 PD-HU3 PD-HA3 PD-HA3 PD-SU1 PD-SU1 VY ISFSI ICs/EAL NEI 99-01, Rev. 6, Section 8 -ISFSI ICs/ EALs E-HU1 E-HU1 8.0 8.1 8.2 ATrACHMENTS Attachment 1, Recognition Category PD EAL Bases Attachment 2, Recognition Category E EAL Basis Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 15 of 51 Attachment 1 -Recognition Category PD EAL Bases 8.1 Attachment 1 -Recognition Category PD EAL Bases Recognition Category PD provides a stand-alone set of ICs/EALs for a Permanently Defueled nuclear power plant to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the plant had operated under a 10 CFR § 50 license and that the operating company has permanently ceased plant operations.

Further, the company intends to store the spent fuel within the plant for some period of time.When in a permanently defueled condition, the plant licensee typically receives approval from the NRC for exemption from specific emergency planning requirements.

These exemptions reflect the lowered radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation.

Source terms and accident analyses associated with plausible accidents are documented in the station's Final Safety Analysis Report (FSAR), as updated. As a result, each licensee will need to develop a site-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses as documented in the station's FSAR.Recognition Category PD uses the same ECLs as operating reactors; however, the source term and accident analyses typically limit the ECLs to an Unusual Event and Alert. The Unusual Event ICs provide for an increased awareness of abnormal conditions while the Alert ICs are specific to actual or potential impacts to spent fuel. The source terms and release motive forces associated with a permanently defueled plant would not be sufficient to require declaration of a Site Area Emergency or General Emergency.

A permanently defueled station is essentially a spent fuel storage facility with the spent fuel is stored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) and shield from direct radiation.

These primary functions of the spent fuel storage pool are the focus of the Recognition Category PD ICs and EALs. Radiological effluent IC and EALs were included to provide a basis for classifying events that cannot be readily classified based on an observable events or plant conditions alone.Appropriate ICs and EALs from Recognition Categories A, C, F, H, and S were modified and included in Recognition Category PD to address a spectrum of the events that may affect a spent fuel pool. The Recognition Category PD ICs and EALs reflect the relevant guidance in this document (e.g., the importance of avoiding both over-classification and under-classification).

Nonetheless, each licensee will need to develop their emergency classification scheme using the NRC-approved exemptions, and the source terms and accident analyses specific to the licensee.

Security-related events will also need to be considered.

The following table, Table PD-i: Recognition Category "PD" Initiating Condition Matrix, provides a summary of initiating conditions associated with Recognition Category PD.Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 16 of 51 Attachment 1 -Recognition Category PD EAL Bases Table PD-I: Recognition Category "PD" Initiating Condition Matrix UNUSUAL EVENT ALERT PD-AU1 Release of gaseous or liquid PD-AA1 Release of gaseous or liquid radioactivity greater than 2 times the ODCM radioactivity resulting in offsite dose greater limits for 60 minutes or longer, than 10 mrem TEDE or 50 mrem thyroid CDE.PD-AU2 UNPLANNED rise in plant radiation PD-AA2 UNPLANNED rise in plant radiation levels. levels that impedes plant access required to maintain spent fuel integrity.

PD-HU1 Confirmed SECURITY CONDITION PD-HA1 HOSTILE ACTION within the or threat. OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.PD-HU2 Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.PD-HU3 Other conditions exists which in the PD-HA3 Other conditions exists which in the judgment of the Emergency Director warrant judgment of the Emergency Director warrant declaration of an Unusual Event. declaration of an Alert.PD-SU1 UNPLANNED spent fuel pool temperature rise.Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 17 of 51 Attachment 1 -Recognition Category PD EAL Bases Category: Initiating Condition:

A- Abnormal Rad Levels/Rad Effluent Release of gaseous or liquid radioactivity greater than 2 times the radiological effluent Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.EAL: PD-AU1.1 Reading on an effluent radiation monitor greater than the values shown for 60 minutes or longer.Gaseous Action Value Gas-1 [RM-17-1561 2 X High Alarm Gas-2 [RM-17-157]

2 X High Alarm Liquid Action Value SW Discharge Hdr Discharge Monitor [RM-17-351]

2 X High Alarm Note 1: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Vermont Yankee Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 18 of 51 Attachment 1 -Recognition Category PD EAL Bases due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL PD-AU1.1 addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).The high alarm setpoint for the Stack Gas Monitor RM-1 7-156/157 (Gas-1 or Gas-2) is established to ensure the ODCM release limits are not exceeded. (Reference 3)In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.The high alarm setpoint for SW Discharge Hdr Discharge Monitor (RM-17-351) is established to ensure the ODCM release limits are not exceeded. (Reference 7)Escalation of the emergency classification level would be via IC PD-AA1.Vermont Yankee Basis Reference(s):

1. VYNPS ODCM 2. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

3. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints 4. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways 5. Alarm Response Sheet (ARS) 9-3-G-7/8 6. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

7. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints 8. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 19 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the radiological effluent Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.EAL: PD-AU1.2 Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer.Note 1: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Vermont Yankee Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL PD-AU 1.2 addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 20 of 51 Attachment 1 -Recognition Category PD EAL Bases Releases in excess of two times the site ODCM (Reference

3) instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release could possibly continue for a prolonged duration.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.Escalation of the emergency classification level would be via IC PD-AA1.Vermont Yankee Basis Reference(s):

1. VYNPS ODCM 2. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

3. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints 4. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways 5. ARS 9-3-G-7/8 6. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

7. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints 8. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 21 of 51 Attachment 1 -Recognition Category PD EAL Bases Category: A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL: PD-AA1.1 Reading on an effluent radiation monitor greater than the values shown for 15 minutes or longer.Gaseous Action Value Gas-1 [RM-17-156]

9.OE+06 cpm Gas-2 [RM-1 7-1571 9.0E+06 cpm Liquid Action Value SW Discharge Hdr Discharge Monitor [RM-17-351]

192 cps Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Note 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis: This EAL addresses a release of gaseous or liquid radioactivity that results in detectable levels offsite that are below 1 % of the EPA PAGs and reflects the condition of an uncontrolled release of gaseous or liquid radioactivity that results in detectable levels at the site boundary.

It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that could potentially exceed regulatory limits (e.g., a significant uncontrolled release).With VY permanently shutdown, the only radionuclide of any significance available to be released in gaseous form is the noble gas Kr-85. Kr-85 decays emitting a low abundance gamma and is therefore not a significant contributor to TEDE.The gaseous release portion of this EAL is not based on any particular dose value, but rather on effluent radiation monitor readings equivalent to 90% of of the full scale reading of the monitors (Reference 11).The liquid release portion of this EAL is based on a counts per second value equivalent to 10 mrem TEDE (Reference 11).Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 22 of 51 Attachment 1 -Recognition Category PD EAL Bases Radiological effluent EALs provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.Vermont Yankee Basis Reference(s):

1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints 3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways 4. ARS 9-3-G-7/8 5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints 7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways 8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring

10. OP 3525 Radiological Coordination

11. Calculation:

Emergency Action Levels for Decommissioning for the Stack and Service Water Discharge Monitors for Vermont Yankee Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 23 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL: PD-AA1,2 Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the site boundary.Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Note 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis: This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hr CDE thyroid, whichever is more limiting.

Actual meteorology is specifically identified because it gives the most accurate dose assessment.

Actual meteorology (including forecasts) should be used whenever possible.For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius around the plant. This corresponds to the Owner Controlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16 (Reference 9).Vermont Yankee Basis Reference(s):

Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 24 of 51 Attachment 1 -Recognition Category PD EAL Bases 1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints 3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways 4. ARS 9-3-G-7/8 5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints 7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways 8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring

10. OP 3525 Radiological Coordination Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 25 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL: PD-AA1.3 Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the site boundary for one hour of exposure.Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Note 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis: This EAL addresses a release of liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hr CDE thyroid, whichever is more limiting.

For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius around the plant. This corresponds to the Owner Controlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16 (Reference 9).Vermont Yankee Basis Reference(s):

1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 26 of 51 Attachment 1 -Recognition Category PD EAL Bases 3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways 4. ARS 9-3-G-7/8 5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints 7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways 8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring 10.OP 3525 Radiological Coordination Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 27 of 51 Attachment 1 -Recognition Category PD EAL Bases Category: Initiating Condition:

A -Abnormal Rad Levels/Rad Effluent Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL: PD-AA1.4 Field survey results indicate EITHER of the following at or beyond the site boundary:* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Note 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis: This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hr CDE thyroid, whichever is more limiting.

For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius around the plant. This corresponds to the Owner Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 28 of 51 Attachment 1 -Recognition Category PD EAL Bases Controlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16 (Reference 9).Vermont Yankee Basis Reference(s):

1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints 3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways 4. ARS 9-3-G-7/8 5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints 7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways 8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring 10.OP 3525 Radiological Coordination Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 29 of 51 Attachment 1 -Recognition Category PD EAL Bases Category: A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

UNPLANNED rise in plant radiation levels.EAL: PD-AU2.1 a. UNPLANNED water level drop in the spent fuel pool as indicated by ANY of the following:

• Spent Fuel Pool low water level alarm as monitored by LT-19-63A and B* Visual observation AND b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors." ARM #14 Rx Bldg West Refuel* ARM #15 Spent Fuel Floor Vermont Yankee Basis: This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.A water level decrease will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel or video camera observations (if available).

A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

Note that PDAU2.1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop.Loss of inventory from the spent fuel pool may reduce water shielding above spent fuel and cause unexpected increases in plant radiation.

Classification as an Unusual Event is warranted as a precursor to a more serious event.The low water level alarm (SFP level 36 ft. 7 in.) in this EAL refers to the SFP low level alarm (Reference 1).The SFP level is monitored by two transmitters (LT-1 9-63A and B).Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 30 of 51 Attachment 1 -Recognition Category PD EAL Bases Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decay heat removal and creating an extremely hazardous radiation environment.

Technical Specifications (Reference

4) require SFP level to be maintained at least 36 ft.Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include (References 3 and 4): " ARM-14 Rx Bldg West Refuel" ARM-15 Spent Fuel Pool The ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station. If radiation levels exceed a preset limit in any channel, the Control Room annunciator and local alarms will be energized to warn of abnormal or significantly changing radiological conditions.

The alarm limit is normally set at approximately 10 times normal background for each channel. (References 5 and 6)It is recognized that some plant area radiation monitors may not be able to detect or display a reading that is 25 mR/hr over NORMAL LEVELS. The intent of this IC is to rely on currently installed plant monitors and not to require design changes/backfits.

In cases where an installed area radiation monitor cannot detect or display values at or above 25 mR/hr over NORMAL LEVELS, then survey instrument results may be used.Routine and work specific surveys are conducted throughout the station at frequencies specified by Radiation Protection management.

Routine surveys are scheduled per the RP Department Surveillance Schedule.

Work specific surveys are conducted in accordance with the Radiation Work Permit (RWP). (Reference 7)Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.Vermont Yankee Basis Reference(s):

1. ARS 21009, FPC Alarm Response Sheets 2. ON 3157 Loss of Fuel Pool Level 3. ON 3153 Excessive Radiation Levels 4. Technical Specification Section 3.12.C Fuel Storage Pool Water Level 5. ON 3153 Excessive Radiation Levels 6. OP 2135 Area Radiation Monitoring System 7. OP 4530 Dose Rate Radiation Surveys Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 31 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

UNPLANNED rise in plant radiation levels.EAL: PD-AU2.2 Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS*.* Normal levels can be considered as the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding the current peak value.Vermont Yankee Basis: This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.The effects of planned evolutions should be considered.

Note that PD-AU2.2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

Loss of inventory from the SFP may reduce water shielding above spent fuel and cause unexpected increases in plant radiation.

Classification as an Unusual Event is warranted as a precursor to a more serious event.The low water level alarm (SFP level 36 ft. 7 in.) in this EAL refers to the SFP low level alarm (Reference 1).The SFP level is monitored by two transmitters (LT-19-63A and B).Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decay heat removal and creating an extremely hazardous radiation environment.

Technical Specifications (Reference

4) require SFP level to be maintained at least 36 ft.Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include (References 3 and 4): " ARM-14 Rx Bldg West Refuel" ARM-15 Spent Fuel Pool The ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station. If radiation levels exceed a preset limit in any channel, the Control Room annunciator and local alarms will be energized to warn of abnormal or significantly changing radiological conditions.

The alarm limit is normally set at approximately 10 times normal background for each channel. (References 5 and 6)It is recognized that some plant area radiation monitors may not be able to detect or display a reading that is 25 mR/hr over NORMAL LEVELS. The intent of this IC is to rely on currently Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 32 of 51 Attachment 1 -Recognition Category PD EAL Bases installed plant monitors and not to require design changes/backfits.

In cases where an installed area radiation monitor cannot detect or display values at or above 25 mR/hr over NORMAL LEVELS, then survey instrument results may be used.Routine and work specific surveys are conducted throughout the station at frequencies specified by Radiation Protection management.

Routine surveys are scheduled per the Radiation Protection Department Surveillance Schedule.

Work specific surveys are conducted in accordance with the Radiation Work Permit. (Reference 7)Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.Vermont Yankee Basis Reference(s):

1. ARS 21009, FPC Alarm Response Sheets 2. ON 3157 Loss of Fuel Pool Level 3. ON 3153 Excessive Radiation Levels 4. Technical Specification Section 3.12.C Fuel Storage Pool Water Level 5. ON 3153 Excessive Radiation Levels 6. OP 2135 Area Radiation Monitoring System 7. OP 4530 Dose Rate Radiation Surveys Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 33 of 51 Attachment 1 -Recognition Category PD EAL Bases Category: A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

EAL: PD-AA2.1 UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

0 Control Room Vermont Yankee Basis: This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity.

As used here, 'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine in another IC may be applicable.

Areas that meet this threshold include the Control Room. There are no permanently installed Control Room area radiation monitors that may be used to assess this EAL threshold.

Therefore these thresholds must be assessed via local radiation survey (Reference 1).An emergency declaration is not warranted if any of the following conditions apply:* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Vermont Yankee Basis Reference(s):

1. OP 4530 Dose Rate Radiation Surveys Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 34 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

EAL: PD-AA2.2 Survey results that indicate an UNPLANNED rise of 100 mR/hr over NORMAL LEVELS*that impedes access to ANY of the following areas needed to maintain control of radioactive material or operation of systems needed to maintain spent fuel pool integrity.

• Spent Fuel Pool Pump Area* Normal levels can be considered as the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding the current peak value.Vermont Yankee Basis: This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity.

As used here, 'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine in another IC may be applicable.

Areas that meet this threshold include the Spent Fuel Pool Pump Area. There are no permanently installed Spent Fuel Pool Pump Area area radiation monitors that may be used to assess this EAL threshold.

Therefore, these thresholds must be assessed via local radiation survey (Reference 1).For EAL PD-AA2.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply:* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 35 of 51 Attachment 1 -Recognition Category PD EAL Bases* The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Vermont Yankee Basis Reference(s):

1. OP 4530 Dose Rate Radiation Surveys Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 36 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

H -Hazards and Other Conditions Affecting Plant Safety Initiating Condition:

Confirmed SECURITY CONDITION or threat.EAL: PD-HU1-.1 A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

Vermont Yankee Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.1 references the Security Shift Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.390 information.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Physical Security Plan.OP 3132, Operations Department Response to Security Events, (Reference

3) provides guidance for response to security related events based on contingency events at the Vermont Yankee Plant.Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAl.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan 2. OP 3132 Operations Department Response to Security Events 3. SP 0904 Contingency Procedures and Events 4. ON 3177 Operations Response to Aircraft Threats Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 37 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

H -Hazards and Other Conditions Affecting Plant Safety Initiating Condition:

Confirmed SECURITY CONDITION or threat.EAL: PD-HU1-.2 Notification of a credible security threat directed at the site.Vermont Yankee Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP 3132, Operations Department Response to Security Events, and SP 0904, Contingency Procedures and Events.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Physical Security Plan.OP 3132, Operations Department Response to Security Events, (Reference

3) provides guidance for response to security related events based on contingency events at the Vermont Yankee Plant.Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan 2. OP 3132 Operations Department Response to Security Events 3. SP 0904 Contingency Procedures and Events 4. ON 3177 Operations Response to Aircraft Threats Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 38 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

H -Hazards and Other Conditions Affecting Plant Safety Initiating Condition:

Confirmed SECURITY CONDITION or threat.EAL: PD-HU1 .3 A validated notification from the NRC providing information of an aircraft threat.Vermont Yankee Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.3 addresses the threat from the impact of an aircraft on the plant. The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may also be provided by the NORAD through the NRC. Validation of the threat is performed in accordance with ON 3177, Operations Response to Aircraft Threats.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Physical Security Plan.OP 3132, Operations Department Response to Security Events, (Reference

3) provides guidance for response to security related events based on contingency events at the Vermont Yankee Plant.Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAl.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan 2. OP 3132 Operations Department Response to Security Events 3. SP 0904 Contingency Procedures and Events 4. ON 3177 Operations Response to Aircraft Threats Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 39 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

H -Hazards and Other Conditions Affecting Plant Safety Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.EAL: PD-HA1.1 A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.

Vermont Yankee Basis: This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of OROs, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.PD-HAl.1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located within the OWNER CONTROLLED AREA.The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 40 of 51 Attachment 1 -Recognition Category PD EAL Bases Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.OP 3132, Operations Department Response to Security Events (Reference

2) provides guidance for response to security related events based on contingency events at VY.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan 2. OP 3132 Operations Department Response to Security Events 3. ON 3177 Operations Response to Aircraft Threats Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 41 of 51 Attachment 1 -Recognition Category PD EAL Bases Category:

H -Hazards and Other Conditions Affecting Plant Safety Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.EAL: PD-HA1.2 A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.Vermont Yankee Basis: This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of OROs, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.PD-HA1.2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with ON 3177, Operations Response to Aircraft Threats.The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 42 of 51 Attachment 1 -Recognition Category PD EAL Bases Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.OP 3132, Operations Department Response to Security Events (Reference

2) provides guidance for response to security related events based on contingency events at VY.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan 2. OP 3132 Operations Department Response to Security Events 3. ON 3177 Operations Response to Aircraft Threats Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 43 of 51 Attachment 1 -Recognition Category PD EAL Bases H -Hazards and Other Conditions Affecting Plant Safety Category: Initiating Condition:

Hazardous event affecting equipment necessary for spent fuel cooling.EAL: PD-HU2.1 a. The occurrence of ANY of the following hazardous events:* Seismic Event (earthquake)

• Internal or external flooding event* River water level >250 ft. MSL (plant grade)* Intake water level < 210 ft. MSL* High winds or tornado strike" FIRE* EXPLOSION" Other events with similar hazard characteristics as determined by the Shift Manager AND b. The event has damaged at least one train of a system needed for spent fuel cooling.AND c. The damaged train(s) cannot, or potentially cannot, perform its designed function based on EITHER: " Indications of degraded performance" VISIBLE DAMAGE Vermont Yankee Basis: This IC addresses a hazardous event that causes damage to at least one train of a system needed for spent fuel cooling. The Service Water System and SFP Cooling systems are the systems necessary to maintain SFP cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its design function.

This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the plant.Plant Grade is 250 ft. MSL. The maximum water level experienced at the site was 231.4 ft. MSL.The Maximum Probable Flood is 252.5 ft. MSL. Since the entrances to all structures containing equipment necessary for cooling are at elevation 252.5 ft. MSL, they are protected against the MPF. However, water level in excess of plant grade may result in a loss of accessibility.(References 1, 2, 3) Gradients, ranging from 248 feet to 254 feet, are available on the north side of the intake structure wall to assist in classifying this event.Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 44 of 51 Attachment 1 -Recognition Category PD EAL Bases Intake water level less than 210 feet indicates low river water conditions which may threaten the operability of the spent fuel pool cooling system. Intake Bay Level Gauge LI-104-9 on Control Room Panel CRP-9-6 as well as direct observation at the intake structure can be used to ascertain this initiating condition threshold.

For EAL PD-HU2.la, the last bullet is not intended to address component failures within the system such as pump bearing failures, electrical grounds or shorts in a pump, failure of valves, etc. Declaration of an event due to the failure of a component would be based on PD-SU1 .1.For EAL PD-HU2.1c, the first bullet addresses damage to a system that is in service/operation since indications for it will be readily available.

For EAL PD-HU2.1c, the second bullet addresses damage to a system that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.Vermont Yankee Basis Reference(s):

1. OP 3127, Natural Phenomena 2. FSAR Section 2.4.3.4 3. FSAR Section 2.4.8 4. ON 3148, Loss of Service Water Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 45 of 51 Attachment 1 -Recognition Category PD EAL Bases H -Hazards and Other Conditions Affecting Plant Safety Category: Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Unusual Event.EAL: PD-HU3.1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Vermont Yankee Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Unusual Event.The Emergency Director is the designated onsite individual having the responsibility and authority for implementing the Vermont Yankee Emergency Plan. The Shift Manager (SM)initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures.

If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations.

In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but plant management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (Reference 1).Vermont Yankee Basis Reference(s):

1. Vermont Yankee Emergency Plan Section 8.0, Organization Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 46 of 51 Attachment 1 -Recognition Category PD EAL Bases H -Hazards and Other Conditions Affecting Plant Safety Category: Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.EAL: PD-HA3.1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve a potential substantial degradation of the level of safety of the plant or indicate a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Vermont Yankee Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.The Emergency Director is the designated onsite individual having the responsibility and authority for implementing the Vermont Yankee Emergency Plan. The SM initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures.

If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations.

In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency.

Vermont Yankee Basis Reference(s):

1. Vermont Yankee Emergency Plan Section 8.0, Organization Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 47 of 51 Attachment 1 -Recognition Category PD EAL Bases Category: S -System Malfunction Initiating Condition:

UNPLANNED spent fuel pool temperature rise.EAL: PD-SUI.1 UNPLANNED spent fuel pool temperature rise to greater than 1500F.Vermont Yankee Basis: This IC addresses a condition that is a precursor to a more serious event and represents a potential degradation in the level of safety of the plant. If uncorrected, boiling in the pool will occur, and result in a loss of pool level and increased radiation levels.Whenever irradiated fuel is stored in the spent fuel pool, the pool water temperature shall be maintained below 150 0 F. The Spent Fuel Pool Cooling System is designed to maintain the pool water temperature below 125 0 F (Reference 1).Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.Vermont Yankee Basis Reference(s):

1. Vermont Yankee Technical Specifications Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 48 of 51 Attachment 2 -Recognition Category E EAL Basses 8.2 Attachment 2 -Recognition Category E EAL Basis Recognition Category E provides a set of ICs/EALs for an ISFSI. An ISFSI is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a cask must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety.An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask confinement boundary is damaged or violated.

This includes classification based on a loaded fuel storage cask confinement boundary loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 49 of 51 Attachment 2 -Recognition Category E EAL Basses Table E-1: Recognition Category "E" Initiating Condition Matrix UNUSUAL EVENT E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.Vermont Yankee Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. 0 Page 50 of 51 Attachment 2 -Recognition Category E EAL Basses Category:

E -Independent Spent Fuel Storage Istallation Initiating Condition:

Damage to a loaded cask CONFINEMENT BOUNDARY EAL: E-HU1.1 Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading greater than two times the ISFSI Technical Specification allowable levels.Vermont Yankee Basis: This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The Technical Specification multiple of two times is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.Minor surface damage that does not affect the storage cask boundary is excluded from the scope of this EAL.Two times the ISFSI Technical Specification allowable levels equate to:* 2.88 mR/hr on the top of the overpack or* 1.90 mR/hr on the side of the overpack, excluding inlet and outlet ducts. (Reference 1)Security-related events for ISFSls are covered under IC PD-HU1 and PD-HA1.Vermont Yankee Basis Reference(s):

1. Entergy Nuclear 10 CFR 72.212 Evaluation Report Appendix G VY Specific Information for ISFSls Utilizing the Holtec, International HI-STORM 100 Cask System 2. VYNPS Procedure 2530 Radiological Monitoring for Dry Fuel Storage 3. VYNPS Procedure DP 3201 Equipment Handling and Storage Abnormal Conditions

4. VYNPS Procedure OP3127 Natural Phenomena Permanently Defueled EAL Technical Bases Vermont Yankee Nuclear Power Station Rev. 0 Page 51 of 51 BVY 14-033 Docket 50-271 Attachment 4 Vermont Yankee Nuclear Power Station Permanently Defueled Emergency Action Level Scheme

BVY 14-033 Docket 50-271 Attachment 5 Vermont Yankee Nuclear Power Station Comparison Matrix for Permanently Defueled EALs Based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 Page 1 of 59 COMPARISON DOCUMENT FOR PERMANENTLY DEFUELED EALS BASED UPON NUCLEAR ENERGY INSTITUTE (NEI) 99-01,"METHODOLOGY FOR DEVELOPMENT OF EMERGENCY ACTION LEVELS," REVISION 6 The following provides a description of the Vermont Yankee Nuclear Power Station (VY)Emergency Action Level (EAL) Technical Bases Document (provided as Attachment 3 to this submittal) and includes the results of a comparison of the EAL matrix against the corresponding information contained in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6.Description of EAL Technical Basis Document 1.0 Purpose A comparison between this section and NEI 99-01 was not made. The VY EAL Technical Bases Document includes reference to the Recognition Category "PD" based on the facility's permanently shutdown and defueled condition, providing a stand-alone set of Initiating Conditions (ICs)/EALs for a permanently defueled nuclear power facility.2.0 Discussion This section was developed based on information contained in NEI 99-01 Rev. 6, Section 1,"Regulatory Background." Differences between the VY Permanently Defueled (PD) EALs Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.* NEI 99-01, Section 1.1, "Operating Reactors," was excluded as it pertains to operating reactors.

VY has permanently ceased operation.

• NEI 99-01, Section 1.5, "Applicability to Advanced and Small Modular Reactor Designs," was excluded because it does not apply to VY.3.0 Key Terminology Used This section was developed based on information contained in NEI 99-01, Section 2, "Key Terminology Used in NEI 99-01 ." Differences between the VY PD EALs Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.* References to Site Area Emergency and General Emergency were removed throughout the section. EALs have been developed using Section 8 for Independent Spent Fuel Storage Installation (ISFSI) and Appendix C for Permanently Defueled Station ICs/EALs.Emergency Classification Levels only include Notification of Unusual Event (Unusual Event) and Alert.* In Section 3.2, "Initiating Condition (IC)" (Section 2.2 of NEI 99-01, Rev. 6), references to RCS Leakage and fission product barriers were removed. Upon permanent cessation of operations, the RCS and Containment will no longer be considered fission product barriers because the reactor will be permanently defueled.

Page 2 of 59* NEI 99-01, Section 2.4, "Fission Product Barrier Threshold," was excluded for reasons previously identified related to fission product barriers.4.0 Guidance on Making Emergency Classifications This section was developed based on information contained in NEI 99-01, Section 5, "Guidance on Making Emergency Classifications." Differences between the VY PD EAL Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.* In Section 4.1 (Section 5.1 of NEI 99-01), references to fission product barrier thresholds were removed as the RCS and Containment no longer serve as fission product barriers.* In Section 4.1 (Section 5.1 of NEI 99-01), the second paragraph of NEI 99-01 stating that, "regulations require the licensee to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes," was excluded.

As detailed in draft NSIR/DPR-ISG-02, Interim Staff Guidance, "Emergency Planning Exemption Requests for Decommissioning Plants," "...the NRC did not include requirements in the 2011 EP Final Rule for non-power reactor licensees to assess, classify, and declare an emergency condition within 15 minutes and promptly declare an emergency condition.

The staff considered the similarity between a permanently defueled reactor and a non-power reactor for the low likelihood of any credible accident resulting in radiological releases requiring offsite protective measures." Analyses were included in "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," BVY 14-009, dated March 14, 2014 (ADAMS Accession No.ML14080A141) (TAC No. MF3614) indicting that, within 15.4 months after shutdown, no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary.

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, VY will make notifications to the State of Vermont within 60 minutes of declaration of an event. In the permanently defueled condition, the rapidly developing scenarios associated with events initiated during reactor power operation are no longer credible.The radiological consequences resulting from the only remaining events (e.g., fuel handling accident) develop over a significantly longer period. As such, a 15 minute notification requirement is unnecessarily restrictive.

Sixty minutes provides a reasonable amount of time to provide notification to state and local governmental.

This notification timeliness is also consistent with the notification requirement to the NRC Operations Center, contained in 10 CFR 50.72(a)(1)(i), for the declaration of an emergency class." In Section 4.2 (Section 5.2 in NEI 99-01), reference to Operating Mode Applicability was removed because Operating Modes are not applicable in a permanently defueled facility.* NEI 99-01, Section 5.4 was excluded because mode changes during classification are not applicable to a permanently defueled facility.

Page 3 of 59* In Section 4.3 (Section 5.3 of NEI 99-01), references to two units were removed because VY is a single unit site.* In Section 4.4 (Section 5.5 of NEI 99-01), the word "levels" was changed to "level" because there is only one higher emergency classification level above an Unusual Event for a permanently defueled facility.* In Section 4.5 (Section 5.6 of NEI 99-01), references to Site Area Emergency and General Emergency were removed. Site Area Emergency and General Emergency are no longer credible emergency classifications because analyses have been developed indicting that, within 15.4 months after shutdown, no credible accident at VY will result in radiological releases requiring offsite protective actions.* In Section 4.6 (Section 5.7 of NEI 99-01) references to an operating plant short-lived event (reactor trip) were removed and replaced with verbiage applicable to a permanently defueled facility.* In Section 4.7 (Section 5.8 of NEI 99-01) the example was removed because an emergency declaration associated with the auxiliary feedwater system is no longer credible at VY. The reference to the 15 -minute emergency classification was excluded for reasons presented above.5.0 References This section was added to provide Developmental and Implementing References applicable to the VY EAL Technical Bases Document.

No corresponding section is included in NEI 99-01.6.0 Acronyms & Definitions This section was developed based on the information presented in Appendices A and B of NEI 99-01, Rev. 6. The list incorporates only those acronyms used in the VY EAL Technical Bases Document.* The following definitions, included in NEI 99-01, Rev. 6, were excluded because they are not used in the VY PD EAL Technical Bases Document: General Emergency Site Area Emergency* The following key terms necessary for overall understanding of the NEI 99-01 emergency classification scheme were excluded because they are not used in the VY PD EAL Technical Bases Document: Fission Product Barrier Threshold* The key term, Initiating Condition (IC), was revised to change 'lour emergency classification levels" to "two emergency classification levels because Site Area Page 4 of 59 Emergency and General Emergency are not used in the VY PD EAL Technical Bases Document.* The key term, Emergency Classification Level, was revised to exclude reference to Site Area Emergency and General Emergency because they are not used in the VY PD EAL Technical Bases Document." Selected terms used in Initiating Condition and Emergency Action Level statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in NEI 99-01, Rev. 6. Definitions not used in the VY PD EAL Technical Bases Document were excluded.7.0 VYNPS to NEI 99-01 EAL Cross-Reference No corresponding section is included in NEI 99-01, Rev. 6. This section was added to facilitate association and location of a Vermont Yankee EAL within the NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding the development of the Vermont Yankee EALs based on the NEI guidance can be found in the EAL Comparison Matrix.8.0 Attachments

8.1 Attachment

1, Recognition Category PD EAL Bases* Attachment 1 of the VY EAL Technical Bases provides the Permanently Defueled IC/EALs and incorporates Appendix C of NEI 99-01, Rev. 6." Reference to Section 3 of NEI 99-01, Rev. 6 was excluded.* References to Operating Modes were removed from Table PD-i.* The table below provides a comparison of the VY PD EALs against the corresponding information contained in NEI 99-01, Rev. 6.8.2 Attachment 2, Recognition Category E EAL Basis* Attachment 2 of the VY EAL Technical Bases provides the ISFSI IC/EALs and incorporates Section 8 of NEI 99-01, Rev. 6.* Reference to Operating Mode was removed from Table E-1." The table below provides a comparison of the VY ISFSI EALs against the corresponding information contained in NEI 99-01, Rev. 6.NEI 99-01 Sections Not Included The following sections of NEI 99-01, Rev. 6 were not included and references made to these sections were also removed:* Section 3, "Design of the NEI 99-01 Emergency Classification Scheme" Page 5 of 59* Section 4, "Site-Specific Scheme Development Guidance" The following sections of NEI 99-01, Rev. 6 were removed from the VY PD EAL matrix as these do not apply to a permanently defueled facility: " Section 6, Abnormal Rad Levels/Radiological Effluent ICs/EALs,* Section 7, Cold Shutdown/Refueling System Malfunction ICs/EALs,* Section 9, Fission Product Barrier ICs/EALs," Section 10, Hazards and Other Conditions Affecting Plant Safety ICs/EALs, and* Section 11, System Malfunction ICs/EALs.

Page 6 of 59 NEI 99-01 Rev 6 Appendix C -Permanently Defueled Station ICs/EALs Proposed EAL Matrix for VY Comparison PD-AU1 ECL: Notification of Unusual Event Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: (1 or 2)Notes:* The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.PD-AU1 Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the radiological effluent Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.* Removed Emergency Classification Level (ECL)" Added Recognition Category* Removed Operating Mode Applicability as it does not apply in a permanently defueled condition* Removed "Example Emergency Action Levels"" Changed numbering of EALs to separate EALs 1 and 2 into separate EALs* Added numbers to bulleted Notes and relocated notes after each EAL Page 7 of 59 NEI 99-01 Rev 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (1) Reading on ANY effluent radiation PD-AU1.1 Reading on an effluent radiation , Replaced "2 times the alarm setpoint monitor greater than 2 times the alarm monitor greater than the values established by a current radioactivity setpoint established by a current shown for 60 minutes or longer, discharge permit" with a table that includes radioactivity discharge permit for 60 Gaseous Action Value VY-specific radiation monitors and action minutes or longer. Gas-1 [RM-17-156]

2 X High Alarm values of "2 x High Alarm" for gaseous and Gas-2 [RM-17-157]

2 X High Alarm liquid release monitors.Liquid Action Value SW Discharge Hdr Discharge Monitor 2 X High Alarm[RM-17-351]

NOTE 1: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.NOTE 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.NOTE 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Basis: Vermont Yankee Basis: Added VY-specific basis information This IC addresses a potential decrease in the This IC addresses a potential decrease in the level of safety of the plant as indicated by a level of safety of the plant as indicated by a low-low-level radiological release that exceeds level radiological release that exceeds regulatory commitments for an extended period regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological includes any gaseous or liquid radiological release, monitored or un-monitored, including release, monitored or un-monitored, including those for which a radioactivity discharge permit those for which a radioactivity discharge permit Page 8 of 59 NEI 99-01 Rev 6 Appendix C -Permanently Proposed EAL Matrix for MY Comparison Defueled Station ICs/EALs is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 -This EAL addresses radioactivity EAL PD-AU 1.1 addresses radioactivity releases Page 9 of 59 NEI 99-01 Rev 6 Appendix C -Permanently Proposed EAL Matrix for MY Comparison Defueled Station ICs/EALs releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).EAL #2 -This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC PD-AA1.that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).The high alarm setpoint for the Stack Gas Monitor RM-17-156/157 (Gas-1 or Gas-2) is established to ensure the ODCM release limits are not exceeded.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.The high alarm setpoint for SW Discharge Hdr Discharge Monitor (RM-17-351) is established to ensure the ODCM release limits are not exceeded.Escalation of the emergency classification level would be via IC PD-AA1.

Page 10 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (2) Sample analysis for a gaseous or liquid PD-AU1.2 Sample analysis for a gaseous or

• No differences release indicates a concentration or liquid release indicates a release rate greater than 2 times the concentration or release rate greater (site-specific effluent release controlling than 2 times the ODCM limits for 60 document) limits for 60 minutes or minutes or longer.longer. NOTE 1: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.NOTE 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.NOTE 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Basis: Vermont Yankee Basis: Added VY-specific basis information This IC addresses a potential decrease in the This IC addresses a potential decrease in the level of safety of the plant as indicated by a level of safety of the plant as indicated by a low-low-level radiological release that exceeds level radiological release that exceeds regulatory commitments for an extended period regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological includes any gaseous or liquid radiological release, monitored or un-monitored, including release, monitored or un-monitored, including those for which a radioactivity discharge permit those for which a radioactivity discharge permit is normally prepared.

is normally prepared.Nuclear power plants incorporate design Nuclear power plants incorporate design features intended to control the release of features intended to control the release of radioactive effluents to the environment, radioactive effluents to the environment.

Page 11 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 -This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL PD-AU1.2 addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, Page 12 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs pathways (e.g., radwaste, waste gas).EAL #2 -This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC PD-AA1.etc.).Releases in excess of two times the site ODCM instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release could possibly continue for a prolonged duration.in a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.Escalation of the emergency classification level would be via IC PD-AAi.

Page 13 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-AA1 ECL: Alert Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: (1 or 2 or 3 or 4)Notes: " The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

PD-AA1 Category:

A -Abnormal Rad Levels/Rad Effluent Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE." Removed ECL" Added Recognition Category* Removed Operating Mode Applicability as it does not apply in a permanently defueled condition" Removed "Example from Emergency Action Levels"" Changed numbering of EALs and separated EALs 1, 2, 3 and 4 into separate EALs" Added numbers to bulleted Notes and relocated notes after each EAL Page 14 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values)PD-AA1.1 Reading on an effluent radiation monitor greater than the value shown for 15 minutes or longer: Gaseous Action Value Gas-1 [RM-17-156]

9.OE+06 cpm Gas-2 [RM-17-157]

9.OE+06 cpm Liquid Action Value SW Discharge Hdr Discharge 192 cps Monitor [RM-17-351

] I NOTE 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.NOTE 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.NOTE 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.NOTE 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

VY no longer has the source term or motive force from a credible accident to create a gaseous release resulting in offsite dose equal to 10 mrem TEDE or 50 mrem thyroid ODE. Therefore, this Initiating Condition does not directly apply to VY as written in the NEI 99-01, Rev. 6 guidance for gaseous releases.

Any releases associated with fuel damage caused by credible fuel handling accidents would be monitored by RM-17-156 and RM-17-157.

Therefore using the Initiating Condition dose values of 10 mrem TEDE and 50 mrem thyroid CDE is not practicable and would result in count rates that exceed the capacity of the gaseous effluent monitors at small fractions of the 10 mrem TEDE or 50 mrem thyroid CDE. Using effluent radiation monitor readings equivalent to 90% of full scale of the monitor range more accurately implements the NEI guidance for the gaseous release portion of this EAL and provides for an appropriate escalation from PD-AU1. The liquid release portion of this EAL is based on a counts per second value equivalent to 10 mrem TEDE Basis: Vermont Yankee Basis: Added VY-specific basis information This IC addresses a release of gaseous or This EAL addresses a release of gaseous or liquid radioactivity that results in projected or liquid radioactivity that results in detectable actual offsite doses greater than or equal to 1% levels that are below 1% of the EPA PAGs and Page 15 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.reflects the condition of an uncontrolled release of gaseous or liquid radioactivity that results in detectable levels at the site boundary.

It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that could potentially exceed regulatory limits (e.g., a significant uncontrolled release).With VY permanently shutdown, the only radionuclide of any significance available to be released in gaseous form is the noble gas Kr-85. Kr-85 decays emitting a low abundance gamma and is therefore not a significant contributor to TEDE.The gaseous release portion of this EAL is not based on any particular dose value, but rather on effluent radiation monitor readings equivalent to 90% of the full scale reading of the monitors.The liquid release portion of this EAL is based on a counts per second value equivalent to 10 mrem TEDE.Radiological effluent EALs provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the Page 16 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.

Page 17 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (2) Dose assessment using actual PD-AA1.2 Dose assessment using actual

• No differences meteorology indicates doses greater meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid than 10 mrem TEDE or 50 mrem CDE at or beyond (site-specific dose thyroid CDE at or beyond the site receptor point), boundary.NOTE 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.NOTE 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.NOTE 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.NOTE 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Basis: Vermont Yankee Basis:

• Added VY-specific basis information This IC addresses a release of gaseous or This EAL addresses a release of gaseous or liquid radioactivity that results in projected or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% actual offsite doses greater than or equal to 1%of the EPA Protective Action Guides (PAGs). It of the EPA PAGs. It includes both monitored includes both monitored and un-monitored and un-monitored releases.

Releases of this releases.

Releases of this magnitude represent magnitude represent an actual or potential an actual or potential substantial degradation of substantial degradation of the level of safety of the level of safety of the plant as indicated by a the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g.,

Page 18 of 59 NEI 99-01 REV 6 Appendix C -Permanently Defueled Station ICs/EALs Proposed EAL Matrix for VY Comparison release).a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hr CDE thyroid, whichever is more limiting.Actual meteorology is specifically identified because it gives the most accurate dose assessment.

Actual meteorology (including forecasts) should be used whenever possible.For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius around the plant. This corresponds to the Owner Controlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16.

Page 19 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (3) Analysis of a liquid effluent sample PD-AA1.3 Analysis of a liquid effluent sample

• No differences indicates a concentration or release rate indicates a concentration or release that would result in doses greater than rate that would result in doses 10 mrem TEDE or 50 mrem thyroid greater than 10 mrem TEDE or 50 CDE at or beyond (site-specific dose mrem thyroid CDE at or beyond the receptor point) for one hour of site boundary for one hour of exposure.

exposure.NOTE 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.NOTE 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.NOTE 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.NOTE 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Basis: Vermont Yankee Basis: Added VY-specific basis information This IC addresses a release of gaseous or This EAL addresses a release of liquid liquid radioactivity that results in projected or radioactivity that results in projected or actual actual offsite doses greater than or equal to 1% offsite doses greater than or equal to 1% of the of the EPA Protective Action Guides (PAGs). It EPA PAGs. It includes both monitored and un-includes both monitored and un-monitored monitored releases.

Releases of this magnitude releases.

Releases of this magnitude represent represent an actual or potential substantial an actual or potential substantial degradation of degradation of the level of safety of the plant as Page 20 of 59 NEI 99-01 REV 6 Appendix C -Permanently Defueled Station ICs/EALs Proposed EAL Matrix for VY Comparison the level of safety of the plant as indicated by a release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hr CDE thyroid, whichever is more limiting.For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius around the plant. This corresponds to the Owner Controlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16.

Page 21 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (4) Field survey results indicate EITHER of the following at or beyond (site-specific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

PD-AA1.4 Field survey results indicate EITHER of the following at or beyond the site boundary:* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer* Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation NOTE 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.NOTE 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.NOTE 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.NOTE 4: The pre-calculated effluent monitor values presented in EAL PD-AAI.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

e No differences Basis: Vermont Yankee Basis: Added VY-specific basis information This IC addresses a release of gaseous or This EAL addresses a release of gaseous or liquid radioactivity that results in projected or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% actual offsite doses greater than or equal to 1%

Page 22 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.In a permanently shutdown and defueled condition, the only credible scenario for releasing gas would be to damage spent fuel during handling.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hr CDE thyroid, whichever is more limiting.For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius around the plant. This corresponds to the Owner Controlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16.

Page 23 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-AU2 PD-AU2

• Removed ECL ECL: Notification of Unusual Event Category:

A -Abnormal Rad Levels/Rad e Added Recognition Category Initiating Condition:

UNPLANNED rise in Effluent

• Removed Operating Mode Applicability as it plant radiation levels. Initiating Condition:

UNPLANNED rise in does not apply in a permanently defueled Operating Mode Applicability:

Not plant radiation levels. condition Applicable

• Removed "Example Emergency Action Example Emergency Action Levels: (1 or 2) Levels" Changed numbering of EALs and separated EALs land 2 into separate EALs (1) a. UNPLANNED water level drop in the PD-AU2.1 a. UNPLANNED water level drop

• No differences spent fuel pool as indicated by ANY of in the spent fuel pool as the following:

indicated by ANY of the (site-specific level indications), following:

AND

• Spent Fuel Pool low water level alarm as monitored by b. UNPLANNED rise in area radiation LT-19-63A and B levels as indicated by ANY of the

• Visual observation following radiation monitors.(site-specific list of area radiation AND monitors).

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors." ARM #14 Rx Bldg West Refuel* ARM #15 Spent Fuel Floor Page 24 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs L Basis: This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.A water level decrease will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel or video camera observations (if available).

A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

Note that EAL #1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop. EAL #2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

Vermont Yankee Basis: This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.A water level decrease will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel or video camera observations (if available).

A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

Note that PDAU2.1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop.Loss of inventory from the spent fuel pool may reduce water shielding above spent fuel and cause unexpected increases in plant radiation.

Classification as an Unusual Event is warranted as a precursor to a more serious event..Added site-VY-specific basis information Escalation of the emergency classification level Page 25 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs would be via IC PD-AA1 or PD-AA2. The low water level alarm (SFP level 36 ft. 7 in.)in this EAL refers to the SFP low level alarm.The SFP level is monitored by two transmitters (LT-19-63A and B).Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decay heat removal and creating an extremely hazardous radiation environment.

Technical Specifications require SFP level to be maintained at least 36 ft.Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include:* ARM-14 Rx Bldg West Refuel* ARM-15 Spent Fuel Pool The ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station. If radiation levels exceed a preset limit in any channel, the Control Room annunciator and local alarms will be energized to warn of abnormal or significantly changing radiological conditions.

The alarm limit is normally set at approximately 10 times normal background for each channel.It is recognized that some plant area radiation monitors may not be able to detect or display a reading that is 25 mR/hr over NORMAL LEVELS. The intent of this IC is to rely on currently installed plant monitors and not to Page 26 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs require design changes/backfits.

In cases where an installed area radiation monitor cannot detect or display values at or above 25 mR/hr over NORMAL LEVELS, then survey instrument results may be used.Routine and work specific surveys are conducted throughout the station at frequencies specified by Radiation Protection management.

Routine surveys are scheduled per the RP Department Surveillance Schedule.

Work specific surveys are conducted in accordance with the Radiation Work Permit (RWP).Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.

Page 27 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (2) Area radiation monitor reading or survey PD-AU2.2 Area radiation monitor reading or , Added definition of NORMAL LEVELS result indicates an UNPLANNED rise of 25 survey result indicates an mR/hr over NORMAL LEVELS. UNPLANNED rise of 25 mR/hr over NORMAL LEVELS*.* Normal levels can be considered as the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding the current peak value.Basis: Vermont Yankee Basis:

• Added site-VY-specific basis information This IC addresses elevated plant radiation This IC addresses elevated plant radiation levels caused by a decrease in water level levels caused by a decrease in water level above irradiated (spent) fuel or other above irradiated (spent) fuel or other UNPLANNED events. The increased radiation UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability levels are indicative of a minor loss in the ability to control radiation levels within the plant or to control radiation levels within the plant or radioactive materials.

Either condition is a radioactive materials.

Either condition is a potential degradation in the level of safety of potential degradation in the level of safety of the the plant. plant.A water level decrease will be primarily The effects of planned evolutions should be determined by indications from available level considered.

Note that PD-AU2.2 excludes instrumentation.

Other sources of level radiation level increases that result from indications may include reports from plant planned activities such as use of radiographic personnel or video camera observations (if sources and movement of radioactive waste available).

A significant drop in the water level materials.

may also cause an increase in the radiation Loss of inventory from the SEP may reduce levels of adjacent areas that can be detected water shielding above spent fuel and cause by monitors in those locations, unexpected increases in plant radiation.

The effects of planned evolutions should be Classification as an Unusual Event is warranted considered.

Note that EAL #1 is applicable only as a precursor to a more serious event.in cases where the elevated reading is due to The low water level alarm (SFP level 36 ft. 7 in.)

Page 28 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs an UNPLANNED water level drop. EAL #2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

Escalation of the emergency classification would be via IC PD-AA1 or PD-AA2.level in this EAL refers to the SFP low level alarm.The SFP level is monitored by two transmitters (LT-19-63A and B).Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decay heat removal and creating an extremely hazardous radiation environment.

Technical Specifications require SFP level to be maintained at least 36 ft.Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include:* ARM-14 Rx Bldg West Refuel* ARM-15 Spent Fuel Pool The ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station. If radiation levels exceed a preset limit in any channel, the Control Room annunciator and local alarms will be energized to warn of abnormal or significantly changing radiological conditions.

The alarm limit is normally set at approximately 10 times normal background for each channel.It is recognized that some plant area radiation monitors may not be able to detect or display a reading that is 25 mR/hr over NORMAL LEVELS. The intent of this IC is to rely on currently installed plant monitors and not to require design changes/backfits.

In cases Page 29 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs where an installed area radiation monitor cannot detect or display values at or above 25 mR/hr over NORMAL LEVELS, then survey instrument results may be used.Routine and work specific surveys are conducted throughout the station at frequencies specified by Radiation Protection management.

Routine surveys are scheduled per the Radiation Protection Department Surveillance Schedule.

Work specific surveys are conducted in accordance with the Radiation Work Permit.Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.

Page 30 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-AA2 PD-AA2 e Removed ECL ECL: Alert Category:

A -Abnormal Rad Levels/Rad

• Added Recognition Category Initiating Condition:

UNPLANNED rise in Effluent

• Removed Operating Mode Applicability as it plant radiation levels that impedes plant access Initiating Condition:

UNPLANNED rise in does not apply in a permanently defueled required to maintain spent fuel integrity, plant radiation levels that impedes plant access condition Operating Mode Applicability:

Not required to maintain spent fuel integrity.

Removed "Example Emergency Action Applicable Levels" Example Emergency Action Levels: (1 or 2) e Changed numbering of EALs and separated EALs 1 and 2 into separate EALs (1) UNPLANNED dose rate greater than 15 PD-AA2.1 UNPLANNED dose rate greater than e No differences mR/hr in ANY of the following areas 15 mR/hr in ANY of the following requiring continuous occupancy to areas requiring continuous maintain control of radioactive material occupancy to maintain control of or operation of systems needed to radioactive material or operation of maintain spent fuel integrity:

systems needed to maintain spent (site-specific area list) fuel integrity:

• Control Room Basis: Vermont Yankee Basis:

• Added VY-specific basis information This IC addresses increased radiation levels This IC addresses increased radiation levels that impede necessary access to areas that impede necessary access to areas containing equipment that must be operated containing equipment that must be operated manually or that requires local monitoring, in manually or that requires local monitoring, in order to maintain systems needed to maintain order to maintain systems needed to maintain spent fuel integrity.

As used here, 'impede' spent fuel integrity.

As used here, 'impede'includes hindering or interfering, provided that includes hindering or interfering, provided that the interference or delay is sufficient to the interference or delay is sufficient to significantly threaten necessary plant access. It significantly threaten necessary plant access. It Page 31 of 59 NEI 99-01 REV 6 Appendix C -Permanently Defueled Station ICs/EALs Proposed EAL Matrix for VY Comparison is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant.This IC does not apply to anticipated temporary increases due to planned events.is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine in another IC may be applicable.

Areas that meet this threshold include the Control Room. There are no permanently installed Control Room area radiation monitors that may be used to assess this EAL threshold.

Therefore these thresholds must be assessed via local radiation survey.An emergency declaration is not warranted if any of the following conditions apply: " The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

Page 32 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (2) UNPLANNED Area Radiation Monitor PD-AA2.2 Survey results that indicate an PD-AA2.2 (EAL 2) was reworded to ensure readings or survey results indicate a UNPLANNED rise of 100 mR/hr over the connection of UNPLANNED was to the rise by 100 mR/hr over NORMAL NORMAL LEVELS* that impedes word "rise" and not to the phrase" Area LEVELS that impedes access to ANY of access to ANY of the following areas Radiation Monitor or survey results".the following areas needed to maintain needed to maintain control of control of radioactive material or radioactive material or operation of Deleted reference to Area Radiation Monitor operation of systems needed to systems needed to maintain spent reading because there are no permanently maintain spent fuel integrity, fuel integrity, installed Spent Fuel Pool Pump Area area radiation monitors that may be used to (site-specific area list)

• Spent Fuel Pool Pump Area assess the EAL threshold and this is the area* Normal levels can be considered as the that must be operated manually to maintain highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding spent fuel pool integrity.

These thresholds the current peak value, must be assessed via local radiation survey.* Added definition of NORMAL LEVELS Basis: Vermont Yankee Basis:

• Added VY-specific basis information This IC addresses increased radiation levels This IC addresses increased radiation levels that impede necessary access to areas that impede necessary access to areas containing equipment that must be operated containing equipment that must be operated manually or that requires local monitoring, in manually or that requires local monitoring, in order to maintain systems needed to maintain order to maintain systems needed to maintain spent fuel integrity.

As used here, 'impede' spent fuel integrity.

As used here, 'impede'includes hindering or interfering, provided that includes hindering or interfering, provided that the interference or delay is sufficient to the interference or delay is sufficient to significantly threaten necessary plant access. It significantly threaten necessary plant access. It is this impaired access that results in the actual is this impaired access that results in the actual or potential substantial degradation of the level or potential substantial degradation of the level of safety of the plant. of safety of the plant. The Emergency Director This IC does not apply to anticipated temporary should consider the cause of the increased increases due to planned events, radiation levels and determine in another IC may be applicable.

Areas that meet this threshold include the Spent Fuel Pool Pump Area. There are no Page 33 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs permanently installed Spent Fuel Pool Pump Area area radiation monitors that may be used to assess this EAL threshold.

Therefore, these thresholds must be assessed via local radiation survey.For EAL PD-AA2.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply:* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a Page 34 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs conservative or precautionary nature, and would not actually prevent or impede a required action.

Page 35 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-HIU1 PD-HU1

• Remove ECL ECL: Notification of Unusual Event Category:

H -Hazards and Other Conditions

• Added Recognition Category Initiating Condition:

Confirmed SECURITY Affecting Plant Safety e Removed Operating Mode Applicability as it CONDITION or threat. Initiating Condition:

Confirmed SECURITY does not apply in a permanently defueled Operating Mode Applicability:

Not CONDITION or threat. condition.

Applicable e Removed "Example Emergency Action Example Emergency Action Levels: (1 or 2 Levels" or 3)

• Changed numbering of EALs and separated EALs 1, 2 and 3 into separate EALs (1) A SECURITY CONDITION that does PD-HU1.1 A SECURITY CONDITION that does .No differences not involve a HOSTILE ACTION as not involve a HOSTILE ACTION as reported by the (site-specific security reported by the Security Shift shift supervision).

Supervisor.

Basis: Vermont Yankee Basis:

• Added VY-specific basis information This IC addresses events that pose a threat to This IC addresses events that pose a threat to plant personnel or the equipment necessary to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus maintain cooling of spent fuel, and thus represent a potential degradation in the level of represent a potential degradation in the level of plant safety. Security events which do not meet plant safety. Security events which do not meet one of these EALs are adequately addressed one of these EALs are adequately addressed by by the requirements of 10 CFR 73.71 or 10 the requirements of 10 CFR 73.71 or 10 CFR CFR 50.72. Security events assessed as 50.72.HOSTILE ACTIONS are classifiable under IC Timely and accurate communications between PD-HAl. Security Shift Supervision and the Control Timely and accurate communications between Room is essential for proper classification of a Security Shift Supervision and the Control security-related event. Classification of these Room is essential for proper classification of a events will initiate appropriate threat-related security-related event. Classification of these notifications to plant personnel and OROs.events will initiate appropriate threat-related Page 36 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]EAL #1 references (site-specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.390 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC.Validation of the threat is performed in accordance with (site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.1 references the Security Shift Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.390 information.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Physical Security Plan.OP 3132, Operations Department Response to Security Events provides guidance for response to security related events based on contingency events at the Vermont Yankee Plant.Security Events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAl.

Page 37 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level would be via IC PD-HA1.

Page 38 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (2) Notification of a credible security threat PD-HU1.2 Notification of a credible security No differences directed at the site. threat directed at the site.Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAI.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references (site-specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of Safeguards and Vermont Yankee Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP 3132, Operations Department Response to Security Events, and SP 0904, Contingency Procedures and Events.Emergency plans and implementing procedures are public documents; therefore, EALs should* Added VY-specific basis information Page 39 of 59 NE! 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs 10 CFR § 2.390 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC.Validation of the threat is performed in accordance with (site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level would be via IC PD-HAI.not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Physical Security Plan.OP 3132, Operations Department Response to Security Events provides guidance for response to security related events based on contingency events at the Vermont Yankee Plant.Security Events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAl.

Page 40 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (3) A validated notification from the NRC PD-HU1.3 A validated notification from the NRC e No differences providing information of an aircraft providing information of an aircraft threat. threat.Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAI.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references (site-specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is Vermont Yankee Basis: This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.3 addresses the threat from the impact of an aircraft on the plant. The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may also be provided by the NORAD through the NRC. Validation of the threat is performed in accordance with ON 3177, 9 Added VY-specific basis information Page 41 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs controlled due to the nature of Safeguards and 10 CFR § 2.390 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC.Validation of the threat is performed in accordance with (site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level would be via IC PD-HA1.Operations Response to Aircraft Threats.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Physical Security Plan.OP 3132, Operations Department Response to Security Events provides guidance for response to security related events based on contingency events at the Vermont Yankee Plant.Security Events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.i ________________________________________________

j Page 42 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-HA1 PD-HA1

• Removed ECL ECL: Alert Category:

H -Hazards and Other Conditions

• Added Recognition Category Initiating Condition:

HOSTILE ACTION within Affecting Plant Safe Removed Operating Mode Applicability as it the OWNER CONTROLLED AREA or airborne Initiating Condition:

HOSTILE ACTION within does not apply in a permanently defueled attack threat within 30 minutes. the OWNER CONTROLLED AREA or airborne condition.

Operating Mode Applicability:

Not Applicable attack Removed "Example Emergency Action Example Emergency Action Levels: (1 or 2) Levels"* Changed numbering of EALs and separated EALs 1, 2 and 3 into separate EALs (1) A HOSTILE ACTION is occurring or has PD-HAI.1 A HOSTILE ACTION is occurring or

• No differences occurred within the OWNER has occurred within the OWNER CONTROLLED AREA as reported by CONTROLLED AREA as reported the (site-specific security shift by the Security Shift Supervisor.

supervision).

Basis: Vermont Yankee Basis:

• Added VY-specific basis information This IC addresses the occurrence of a This IC addresses the occurrence of a HOSTILE ACTION within the OWNER HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an CONTROLLED AREA or notification of an aircraft attack threat. This event will require aircraft attack threat. This event will require rapid response and assistance due to the rapid response and assistance due to the possibility of the attack progressing to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact. the plant and staff for a potential aircraft impact.Timely and accurate communications between Timely and accurate communications between Security Shift Supervision and the Control Security Shift Supervision and the Control Page 43 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for MY Comparison Defueled Station ICs/EALs Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located within Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of OROs, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.PD-HA1.1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located within the OWNER CONTROLLED Page 44 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs the OWNER CONTROLLED AREA.EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with (site-specific procedure).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

AREA.The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the VY Physical Security Plan.OP 3132, Operations Department Response to Security Events, provides guidance for response to security related events based on contingency events at VY.

Page 45 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

Page 46 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs (2) A validated notification from NRC of an PD-HA1.2 A validated notification from e No differences aircraft attack threat within 30 minutes of NRC of an aircraft attack threat the site. within 30 minutes of the site.Basis: This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better Vermont Yankee Basis: This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of OROs, allowing them to be better prepared should it be* Added VY-specific basis information Page 47 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR §50.72.EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located within the OWNER CONTROLLED AREA.EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with (site-specific procedure).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.PD-HA1.2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with ON 3177, Operations Response to Aircraft Threats.The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this Page 48 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.OP 3132, Operations Department Response to Security Events, provides guidance for response to security related events based on contingency events at VY.

Page 49 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-HU2 PD-HU2

• Removed ECL ECL: Notification of Unusual Event Category:

H -Hazards and Other Conditions

• Added Recognition Category Initiating Condition:

Hazardous event Affecting Plant Safe

• Removed reference to "SAFETY SYSTEM".affecting SAFETY SYSTEM equipment Initiating Condition:

Hazardous event This IC addresses a hazardous event that necessary for spent fuel cooling, affecting equipment necessary for spent fuel causes damage to equipment needed for Operating Mode Applicability:

Not cooling, spent fuel cooling. All systems required to Applicable support Spent Fuel Pool cooling will be considered to be within the scope of this EAL.Example Emergency Action Levels: e Removed Operating Mode Applicability as it does not apply in a permanently defueled condition.

e Removed "Example Emergency Action Levels"* Changed numbering of EAL (1) a. The occurrence of ANY of the PD-HU2.1

• Added high river level and low intake level to following hazardous events: a. The occurrence of ANY of the the list of hazardous events. Both are ICs)following hazardous events: that exist presently in the VY EAL matrix and should continue to be considered." Internal or external flooding event o Seismic event (earthquake) 9 Removed reference to "SAFETY SYSTEM"." High winds or tornado strike

• Internal or external flooding Following permanent cessation of operations, FIRE event Spent Fuel Pool cooling will be accomplished F River water level >250 ft. MSL using the Standby Fuel Pool Cooling* EXPLOSION (plant grade) Subsystem (SFPCS). The SFPCS is a two-(plantecfi gr) train system designed to prevent a single* (site-specific hazards)

• Intake water level <210 ft. MSL active failure from disabling both trains. The* Other events with similar hazard

• High winds or tornado strike system consists of two pumps and two heat characteristics as determined by exchangers which are normally lined up as two parallel trains. Each train of the SFPCS Page 50 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs the Shift Manager

• FIRE can be placed in service remotely.AND

• EXPLOSION b. The event has damaged at least one e Other events with similar hazard train of a SAFETY SYSTEM needed characteristics as determined by for spent fuel cooling. the Shift Manager AND AND c. The damaged SAFETY SYSTEM b. The event has damaged at least train(s) cannot, or potentially cannot, one train of a system needed for perform its design function based on spent fuel cooling.EITHER: AND" Indications of degraded c. The damaged train(s) cannot, or performance potentially cannot, perform its" VISIBLE DAMAGE design function based on EITHER: " Indications of degraded performance" VISIBLE DAMAGE Basis: Vermont Yankee Basis: e Added VY-specific basis information This IC addresses a hazardous event that This IC addresses a hazardous event that e Removed reference to "SAFETY SYSTEM".causes damage to at least one train of a causes damage to at least one train of a system Following permanent cessation of operations, SAFETY SYSTEM needed for spent fuel needed for spent fuel cooling. The Service Spent Fuel Pool cooling will be accomplished cooling. The damage must be of sufficient Water System and SFP Cooling systems are using the Standby Fuel Pool Cooling magnitude that the system(s) train cannot, or the systems necessary to maintain SFP cooling. Subsystem (SFPCS). The SFPCS is a two-potentially cannot, perform its design function.

The damage must be of sufficient magnitude train system designed to prevent a single This condition reduces the margin to a loss or that the system(s) train cannot, or potentially active failure from disabling both trains. The potential loss of the fuel clad barrier, and cannot, perform its design function.

This system consists of two pumps and two heat therefore represents a potential degradation of condition reduces the margin to a loss or exchangers which are normally lined up as the level of safety of the plant. potential loss of the fuel clad barrier, and two parallel trains. Each train of the SFPCS Page 51 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs For EAL 1.c, the first bullet addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available.

For EAL 1.c, the second bullet addresses damage to a SAFETY SYSTEM train that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.therefore represents a potential degradation of the level of safety of the plant.Plant Grade is 250 ft. MSL. The maximum water level experienced at the site was 231.4 ft. MSL.The Maximum Probable Flood is 252.5 ft. MSL.Since the entrances to all structures containing equipment necessary for cooling are at elevation 252.5 ft. MSL, they are protected against the MPF. However, water level in excess of plant grade may result in a loss of accessibility.

Gradients, ranging from 248 feet to 254 feet, are available on the north side of the intake structure wall to assist in classifying this event.Intake water level less than 210 feet indicates low river water conditions which may threaten the operability of the spent fuel pool cooling system. Intake Bay Level Gauge LI-104-9 on Control Room Panel CRP-9-6 as well as direct observation at the intake structure can be used to ascertain this initiating condition threshold.

For EAL PD-HU2.1a, the last bullet is not intended to address component failures within the system such as pump bearing failures, electrical grounds or shorts in a pump, failure of valves, etc. Declaration of an event due to the failure of a component would be based on PD-SU1.1.For EAL PD-HU2.1c, the first bullet addresses damage to a system that is in service/operation can be placed in service remotely.The intent of the last bullet in PD-HU2.1a is to consider similar hazards that may cause damage to a system and not intended to include component failures in a system. If a component fails, SFP temperature will be affected and the Shift Manager/Emergency Director (SM/ED) should consider declaration per PD-SU1 if it rises above 150 0 F.

Page 52 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs since indications for it will be readily available.

For EAL PD-HU2.1c, the second bullet addresses damage to a system that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert lCs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.

Page 53 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-HU3 PD-HU3 o Removed ECL ECL: Notification of Unusual Event Category:

H -Hazards and Other Conditions o Added Recognition Category Initiating Condition:

Other conditions exist Affecting Plant Safe o Removed Operating Mode Applicability as it which in the judgment of the Emergency Initiating Condition:

Other conditions exist does not apply in a permanently defueled Director warrant declaration of a (NO)UE. which in the judgment of the Emergency condition.

Operating Mode Applicability:

Not Director warrant declaration of an Unusual OperaingaMoe Apiaiiy o Event. *Removed "Example Emergency Action Applicable ELevels" Example Emergency Action Levels: Changed numbering of EAL (1) Other conditions exist which in the PD-HU3.1 Other conditions exist which in the No differences judgment of the Emergency Director judgment of the Emergency Director indicate that events are in progress or indicate that events are in progress have occurred which indicate a potential or have occurred which indicate a degradation of the level of safety of the potential degradation of the level of plant or indicate a security threat to safety of the plant or indicate a facility protection has been initiated.

No security threat to facility protection releases of radioactive material has been initiated.

No releases of requiring offsite response or monitoring radioactive material requiring offsite are expected unless further degradation response or monitoring are expected of safety systems occurs. unless further degradation of safety systems occurs.

Page 54 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a NOUE.Vermont Yankee Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Unusual Event.The Emergency Director is the designated onsite individual having the responsibility and authority for implementing the Vermont Yankee Emergency Plan. The Shift Manager (SM)initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures.

If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations.

In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but plant management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency.

• Added VY-specific basis information.

Page 55 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-HA3 PD-HA3

• Removed ECL ECL: Alert Category:

H -Hazards and Other Conditions

• Added Recognition Category Initiating Condition:

Other conditions exist Affecting Plant Safe

• Removed Operating Mode Applicability as it which in the judgment of the Emergency Initiating Condition:

Other conditions exist does not apply in a permanently defueled Director warrant declaration of an Alert. which in the judgment of the Emergency condition.

Operating Mode Applicability:

Not Director warrant declaration of an Alert. 9 Removed "Example Emergency Action Applicable Levels" Example Emergency Action Levels:

• Changed numbering of EAL (1) Other conditions exist which in the Emergency Action Levels: e No differences judgment of the Emergency Director PD-HA3.1 Other conditions exist which in the indicate that events are in progress or judgment of the Emergency Director have occurred which involve an actual indicate that events are in progress or potential substantial degradation of or have occurred which involve an the level of safety of the plant or a actual or potential substantial security event that involves probable life degradation of the level of safety of threatening risk to site personnel or the plant or a security event that damage to site equipment because of involves probable life threatening risk HOSTILE ACTION. Any releases are to site personnel or damage to site expected to be limited to small fractions equipment because of HOSTILE of the EPA Protective Action Guideline ACTION. Any releases are expected exposure levels. to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: Vermont Yankee Basis: Added VY-specific basis information.

This IC addresses unanticipated conditions not This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant addressed explicitly elsewhere but that warrant declaration of an emergency because declaration of an emergency because conditions exist which are believed by the conditions exist which are believed by the Page 56 of 59 Emergency Director to fall under the Emergency Director to fall under the emergency emergency classification level description for classification level description for an Alert.an Alert. The Emergency Director is the designated onsite individual having the responsibility and authority for implementing the Vermont Yankee Emergency Plan. The SM initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures.

If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations.

In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but plant management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency.

Page 57 of 59 NEI 99-01 REV 6 Appendix C -Permanently Proposed EAL Matrix for VY Comparison Defueled Station ICs/EALs PD-SU1 PD-SU1

• Removed ECL ECL: Notification of Unusual Event Category:

S -System Malfunction

• Added Recognition Category Initiating Condition:

UNPLANNED spent fuel Initiating Condition:

UNPLANNED spent fuel e Removed Operating Mode Applicability as it pool temperature rise. pool temperature rise. does not apply in a permanently defueled Operating Mode Applicability:

Not condition.

Applicable

• Removed "Example Emergency Action Example Emergency Action Levels: Levels" (1) UNPLANNED spent fuel pool PD-SU1.1 UNPLANNED spent fuel pool e No differences temperature rise to greater than (site- temperature rise to greater than specific *F). 150 0 F.Basis: Vermont Yankee Basis:

• Added VY-specific Technical Specification This IC addresses a condition that is a This IC addresses a condition that is a information.

precursor to a more serious event and precursor to a more serious event and represents a potential degradation in the level represents a potential degradation in the level of of safety of the plant. If uncorrected, boiling in safety of the plant. If uncorrected, boiling in the the pool will occur, and result in a loss of pool pool will occur, and result in a loss of pool level level and increased radiation levels, and increased radiation levels.Escalation of the emergency classification level Whenever irradiated fuel is stored in the spent would be via IC PD-AA1 or PD-AA2. fuel pool, the pool water temperature shall be maintained below 150 0 F. The Spent Fuel Pool Cooling System is designed to maintain the pool water temperature below 125 0 F.Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.

Page 58 of 59 NEI 99-01 REV 6 Section 8 -ISFSI Proposed EAL Matrix for VY Comparison ICs/EALs EE-HU1 -HU1 , Removed ECL ECL: Notification of Unusual Event Category:

H -Hazards and Other Conditions

° Added Recognition Category Initiating Condition:

Damage to a loaded Affecting Plant Safe Removed Operating Mode Applicability as it cask CONFINEMENT BOUNDARY.

Initiating Condition:

Damage to a loaded does not apply in a permanently defueled Operating Mode Applicability:

All cask CONFINEMENT BOUNDARY.

condition.

Example Emergency Action Levels: Removed "Example Emergency Action Levels" (1) Damage to a loaded cask E-HU1.1 Damage to a loaded cask

• Removed reference to "on-contact".

CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY as indicated by an on-contact radiation indicated by a radiation reading

• Removed "on the surface of the spent fuel reading greater than (2 times the site- greater than two times the ISFSI cask".specific cask specific technical Technical Specification allowable specification allowable radiation level) levels.on the surface of the spent fuel cask.Basis Vermont Yankee Basis:

• Added VY-specific basis information.

The "two This IC addresses an event that results in This IC addresses an event that results in times the ISFSI Technical Specification damage to the CONFINEMENT BOUNDARY damage to the CONFINEMENT BOUNDARY of allowable levels" are included.of a storage cask containing spent fuel. It a storage cask containing spent fuel. It applies

• Removed reference to "on-contact".

applies to irradiated fuel that is licensed for to irradiated fuel that is licensed for dry storage dry storage beginning at the point that the beginning at the point that the loaded storage loaded storage cask is sealed. The issues of cask is sealed. The issues of concern are the concern are the creation of a potential or creation of a potential or actual release path to actual release path to the environment, the environment, degradation of one or more degradation of one or more fuel assemblies fuel assemblies due to environmental factors, due to environmental factors, and and configuration changes which could cause configuration changes which could cause challenges in removing the cask or fuel from challenges in removing the cask or fuel from storage.storage. The existence of "damage" is determined by Page 59 of 59 NEI 99-01 REV 6 Section 8 -ISFSI Proposed EAL Matrix for VY Comparison ICs/EALs The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.Security-related events for ISFSIs are covered under ICs HU1 and HAl.radiological survey. The Technical Specification multiple of two times is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.Minor surface damage that does not affect the storage cask boundary is excluded from the scope of this EAL.Two times the ISFSI Technical Specification allowable levels equate to:* 2.88 mR/hr on the top of the overpack or* 1.90 mR/hr on the side of the overpack, excluding inlet and outlet ducts.Security-related events for ISFSIs are covered under IC PD-HU1 and PD-HAI.