BVY 14-054, Proposed Changes to the Vermont Yankee Emergency Plan - Supplement 2

Proposed Changes to the Vermont Yankee Emergency Plan - Supplement 2

ML14231A019
Person / Time
Site:	Vermont Yankee
Issue date:	08/14/2014
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-054, TAC MF3668
Download: ML14231A019 (43)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd SEntergy Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 14-054 August 14, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Proposed Changes to the Vermont Yankee Emergency Plan - Supplement 2 (TAC No. MF3668)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the Vermont Yankee Emergency Plan," BVY 14-018, dated March 24, 2014 (TAC No. MF3668) (ADAMS Accession No. ML14085A257)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the Vermont Yankee Emergency Plan - Supplement 1 (TAC No. MF3668)," BVY 14-034, dated May 21, 2014 (ADAMS Accession No. ML14149A048)

3. Letter, USNRC to Entergy Nuclear Operations, Inc. "Vermont Yankee Nuclear Power Station - Request For Additional Information Regarding License Amendment Request For Emergency Plan Change (TAC No. MF3668)," NVY 14-055, dated July 1, 2014 (ADAMS Accession No. ML14163A590)

Dear Sir or Madam:

By letter dated March 24, 2014 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) proposed an amendment to Renewed Facility Operating License (OL) DPR-28 for Vermont Yankee Nuclear Power Station (VY). The proposed amendment would revise the site emergency plan (SEP) for the permanently defueled condition. The proposed SEP changes would revise the on-shift staffing and Emergency Response Organization (ERO) staffing levels.

Reference 2 provided a response to an NRC Request for Additional Information (RAI) regarding the proposed SEP changes. In Reference 3, the NRC provided VY with an additional RAI regarding the proposed SEP changes. Attachment 1 of this letter provides the responses to the RAI. Attachment 2 contains revised SEP pages and Attachment 3 contains an updated summary of the proposed SEP changes.

The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this supplement.

BVY 14-054 / page 2 of 2 This letter contains no new regulatory commitments.

If you have any questions on this transmittal, please contact Mr. Philip Couture at 802-451-3193.

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

Executed on August 14, 2014.

Sincerely, CJW/plc Attachments: 1. Response to Request for Additional Information

2. Revised SEP Pages

3. Updated Tabular Summary of Proposed Changes to SEP 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 08C2A 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 14-054 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Response to Request for Additional Information

BVY 14-054 / Attachment 1 / Page 1 of 12 REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGE ENTERGY NUCLEAR OPERATIONS. INC.

VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 RAI-VY-01 (on Page 2 of 23) states:

NCOs [non-certifiedoperators]will perform duties typically associated with those performed by AOs [auxiliaryoperators]and CROs [control room operators],such as manipulation and monitoring of plant equipment. NCOs will also be assigned to monitor indications and communications in the Control Room.

Please specify what is the level of training provided to the NCOs to perform the duties of the AOs/CROs with respect to operation and monitoring of plant equipment, mitigative strategies, and emergency plan training?

Response

The Non-Certified Operator (NCO) Training Program is currently under development in accordance with 10 CFR 50.120. The NCO position combines the post-shutdown duties of the licensed Reactor Operator (RO) and the non-licensed Auxiliary Operator (AO). The specific training requirements of the NCO position are currently being drafted by the Vermont Yankee (VY) Training Department and have not yet been reviewed and approved by Operations management. The draft training requirements include classroom training in theory and systems topics, administrative procedures, off-normal and transient procedures/mitigation strategies and refuel platform operations. The training program is designed with an emphasis on systems/processes important to maintaining Spent Fuel Pool (SFP) cooling and monitoring and controlling SFP parameters, such as SFP water level and temperature. Consequently, the NCOs will be trained on pertinent Control Room indications and controls that will be monitored and operated to maintain SFP cooling and SFP water level, in addition to plant radiological conditions.

The drafted NCO training program will also include training on applicable aspects of the VY Site Emergency Plan (SEP) related to NCO duties.

Although non-licensed AOs are currently trained to function as the Control Room Communicator, VY makes no specific commitment to train NCOs in this role because it is anticipated that the two Certified Fuel Handlers (CFHs) that will be located in the Control Room during a declared emergency will maintain responsibility for Emergency Plan communications.

Personnel assigned to fill the NCO positions during the post-shutdown period, prior to implementation of the Permanently Defueled Emergency Plan (PDEP), are a mixture of licensed ROs and non-licensed AOs. The majority of the required training for the NCO position will already have been completed by the licensed ROs because they have previously been trained and qualified as both Reactor and Auxiliary Operators to support power operations. The current AOs

BVY 14-054 / Attachment 1 / Page 2 of 12 have been trained and qualified as non-licensed operators only. Therefore it is expected they will require additional training to address skill and knowledge gaps related to Control Room operations.

Once the specific training requirements for the NCO position have been identified using a systematic approach to training, as required by 10 CFR 50.120, a formal gap analysis will be completed for all operators identified to fill the NCO position. Individualized training plans will be developed and completed to address the identified knowledge and skills gaps for the selected NCO candidates. This will include training the currently qualified AOs on Control Room indications, controls and procedures.

RAI-VY-02 (on Page 6 of 23) states:

The OSC [operationssupport center] Manager is the only position required to activate and staff the OSC.

In addition, Section 6.1.2 of the Site Emergency Plan (SEP) states:

It is staffed with sufficient in-plant personnel required to effect protective and corrective actions in support of the emergency situation.

Please explain how the OSC can be staffed with sufficient in-plant personnel required to effect protective and corrective actions in support of the emergency situation if the OSC Manager is the only position required to activate and staff the OSC?

Response

The primary functions of the OSC will remain dispatching of, and accounting for, Repair and Corrective Action Teams and dispatching of Site Boundary and Offsite Monitoring Teams. The OSC Manager is responsible for ensuring adequate staffing of the OSC to support the emergency; working with the Emergency Plant Manager to set priorities for the OSC; and directing the activities of the OSC to support emergency response. If, at any time, the OSC Manager determines additional manpower is necessary to accomplish the mission of the OSC, the OSC Manager will contact the Administration and Logistics Coordinator in the EOF to arrange for augmentation by additional personnel to support the emergency response functions of the OSC.

The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The primary events of concern in the immediate post-shutdown and defueled condition will be a fuel handling accident and a loss of SFP cooling and/or water inventory. During fuel handling activities there will be extra personnel on site that will, were a fuel handling accident to occur, be able to respond to the event. Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). These strategies will also continue to be required as a license condition.

OSC staff is not relied upon to implement SFP inventory makeup.

BVY 14-054 / Attachment 1 / Page 3 of 12 RAI-VY-03 / page 7 of 23 provides:

Table 1 shows the TSC [technicalsupport center] Reactor Engineer has a yes for minimum staff position.

In addition, Attachment 1 (on Page 2 of 23) provides that the TSC Reactor Engineer is a position that ENO proposes to eliminate. These statements are in conflict. Please clarify whether the TSC Reactor Engineer is being retained as minimum staffing or provide justification for removal as a minimum staffing position.

Response

These statements are reconciled as follows. The intent of Table 1 is to compare the current ERO positions against the proposed post-shutdown ERO positions and identify whether each position is currently a minimum staff position. The TSC Reactor Engineer is a position that is being eliminated in the post-shutdown ERO. Table 1 in Attachment 1 of Reference 2 identifies the Reactor Engineer as a current minimum staff position and the position is not included as a proposed position in the post-shutdown ERO upon implementation of the changes identified in Reference 2. of emergency plan procedure EPOP-TSC-3542 outlines the duties of the TSC Reactor Engineer position. Specifically, Section 2.2 of Attachment 5 identifies the duties as follows:

• Assist the Shift Manager, Emergency Plant Manager, TSC Manager and Engineering Coordinator, as necessary.

" Assist operations personnel in calculating and tracking core reactivity.

• Assist the Engineering Coordinator in clarifying core parameter information.

• Perform a core damage assessment if an ATWS [anticipated transient without scram]

condition or fuel failure exists.

• Work with other TSC Engineers to provide support to the Control Room to mitigate the effects of the event and return the plant to a safe condition.

• Assist in Severe Accident Management Guideline implementation, when requested.

" Provide recommendations to plant operators.

• Assist in developing emergency procedures, if needed.

Attachment 5 of Reference 2 identifies three primary duties for the Reactor Engineer, including:

determining and providing an estimate of core damage, assisting in the implementation of Severe Accident Management Guidelines and providing core parameter information results to the TSC Manager. In a permanently shutdown and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. Any other duties described in implementing procedures that are unrelated to core assessment, such as assisting the Emergency Plant Manager, TSC Manager and Engineering Coordinator; assisting with implementation of Severe Accident Management Guidelines; providing recommendations to plant operators; and assisting in developing emergency procedures are either no longer necessary in a permanently defueled condition or will be performed by other members of the post-shutdown ERO.

BVY 14-054 / Attachment 1 / Page 4 of 12 RAI-VY-04 (on Page 8 of 23) states:

ERO duties have been reviewed and duties for eliminated positions will be transferred appropriately.

Please describe by what process has this been validated and documented for the emergency operations facility (EOF) and Joint Information Center (JIC)?

Response

Each current ERO position is identified and the associated duties are captured in the ERO Task Analysis provided in Attachment 5 of Reference 2. The duties of the EOF and JIC positions that are being eliminated were reviewed against NUREG-0654, and VY procedures EN-EP-801, "Emergency Response Organization," EN-TQ-1 10, "Emergency Response Organization Training,"

and EN-TQ-1 10-01, "Fleet Emergency Plan Training Course Summary." Each of the eliminated positions was analyzed to identify the key duties associated with the position and the duties were then evaluated against the planning standards in NUREG-0654.

The Table provided in Attachment 5 of Reference 2 contains columns with headings "Implementing Actions" and 'Task Assigned To?" These columns provide the details for disposition of each task.

This analysis was peer-checked by VY Emergency Planning. Procedures and training materials depicting the changes presented in Attachment 5 of Reference 2 will be developed. Some of the duties are identified as being eliminated because they become unnecessary following permanent cessation of operations and permanent removal of fuel from the reactor vessel. Other duties are identified as eliminated because the duties are performed by other positions of the ERO in the EOF or JIC and will continue to be performed by these positions in the post-shutdown ERO.

The proposed changes to the VY SEP, including the minimal changes made to the ERO to develop the post-shutdown ERO, have been evaluated for impacts on the EOF and the JIC and for the ability of offsite response organizations to implement their FEMA-approved Radiological Emergency Preparedness (REP) Plans. This analysis was provided to the NRC in Reference 3. As described in Reference 3, potential impacts on the ability of State and local response organizations to effectively implement their FEMA-approved REPs do not exist because no tasks that require interfacing with State and local response organizations are proposed for elimination. VY has appropriately addressed elimination of ERO positions that interface with offsite representatives by transferring the necessary tasks to remaining post-shutdown ERO positions.

To validate the results of the analysis described in Reference 3, drills will be developed and conducted in the 4th quarter of 2014, prior to the requested approval date of Reference 2. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each emergency response facility and will utilize the post-shutdown procedures currently being developed depicting the revised assignment of duties. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each emergency response facility, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the SEP,

BVY 14-054 / Attachment 1 / Page 5 of 12 site commitments and applicable regulation. Drill dates will be provided to the NRC in advance and the NRC staff will be provided the opportunity to observe the drills. Additionally, supporting information regarding the drills will be provided to the NRC staff, if requested.

RAI-VY-05 (on Page 10 of 23) states:

When the on-shift Chemistry Technician position is eliminated, the on-shift Radiation Protection Technician will be able to perform sampling and analysis, so as to not delay information potentially needed by the SM [Shift Manager]to determine if an emergency declaration is required.

Please describe what specific training is provided to the on-shift Radiation Protection Technician to be qualified to perform these samples and analyses functions?

Response

The incumbent Radiation Protection (RP) Technicians currently receive specific training modules which prepare them to perform sampling and analysis at various locations throughout the plant.

Similar to Chemistry Technicians, incumbent RP Technicians have been trained on how to analyze these samples using a Multi-Channel Analyzer (MCA). These analyses are performed using an approved station procedure and a computerized MCA menu which guides the technician to select the correct counting geometry for various sample types.

There are no new skills or basic knowledge requirements involved in training incumbent RP Technicians to perform liquid sampling and analysis to support an emergency declaration.

Currently, a Training Evaluation and Action Request (TEAR VTY-2014-163) is tracking the completion of the gap analysis between current RP Technician training requirements and any new specific knowledge requirements associated with emergency plan sampling and analysis. Such specific knowledge requirements would include how to obtain specific liquid samples. This TEAR will also track the completion of any required gap training for the incumbent RP Technicians who have been selected to fill SAFSTOR positions.

The initial training requirements for any new SAFSTOR RP Technician will include all training modules to ensure they are equipped with the required skills and knowledge to perform the required liquid sampling and analysis. These training modules will be specifically identified in the SAFSTOR training program description for the RP Technician position. This document is currently being developed in accordance with the requirements of 10 CFR 50.120.

RAI-VY-06 Attachment 1 (on Page 14 of 23) states:

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

BVY 14-054 / Attachment 1 / Page 6 of 12 Please explain whether the expertise of the TSC Reactor Engineer position would be needed to provide any technical evaluation support for an event in the spent fuel pool (e.g., a drain down event that may require an evaluation of the condition of the fuel to determine any possible recommendations for offsite agencies to consider).

Response

Elimination of the TSC Reactor Engineer position will have no effect on emergency response in a permanently defueled condition because the position does not assess the condition of fuel in the SFP during an emergency. The current TSC Reactor Engineer position satisfies the technical support Core/Thermal Hydraulics position included in Table B-1 of NUREG-0654. TSC Reactor Engineers have expertise in the area of core damage assessment and core parameter monitoring.

Table B-1 does not identify an on-shift position responsible for evaluation of fuel in the SFP during an emergency. TSC Reactor Engineers are not trained to provide this type of technical evaluation.

Instead, offsite technical assistance would need to be obtained to perform this analysis.

RAI-VY-07 Attachment 1, Section 5.2.6 (on Page 17 of 23) states:

The function of these additional resources is to provide RP [radiationprotection]

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

In addition, Attachment 3, Table 8.4 (on Page 2 of 2) provides:

Protective Actions (In Plant) Shift AO/CRO/NCO (2**)2 on shift Note 2. All AOs/CROs/NCOs use digital dosimeters with features for dose rate and total dose monitoring. AOs/CROs/NCOs are trained to self-monitor in an emergency.

The information in Note 2 is not consistent with that provided in Attachment 1, as cited above. There is a difference between self-monitoring and "providing RP oversight" as described in Section 5.2.6.

• Please clarify how RP oversight is provided for search and rescue, and firefighting.

Based on the proposed on-shift staffing, it appears that they may be part of the fire brigade, and therefore, it would be a collateral duty.

• Please clarify how the fire brigade members that may be primarily engaged in firefighting efforts or search and rescue missions are provided RP coverage.

BVY 14-054 / Attachment 1 / Page 7 of 12 Please describe what training is provided that qualifies these two operations positions to perform RP oversight. Please refer to NRC Health Physics Position (HPPOS) 238, "Health Physics Position of Task Qualification of HP Technicians," in developing your response.

Response

The portion of Table 8.4 referenced in the RAI was revised in Reference 2 only to indicate the title change for the Control Room Operator and Auxiliary Operator to Non-Certified Operator and does not represent any changes in radiation protection oversight from the currently assigned responsibilities, Section 8.1 and Table 8.4 of the SEP identify one (1) on-shift RP Technician.

The two operators identified in the portion of Table 8.4 referenced in the RAI are members of the fire brigade. They do not provide RP oversight during firefighting and search and rescue operations. Because the on-shift RP Technician provides RP oversight during search and rescue or firefighting, there are no collateral duties for the operators. The operators are trained to self-monitor in circumstances where it is safe to do so. Access control and personnel monitoring are described in section 5.2.6.1 of Reference 2.

RAI-VY-08 , Section 5.2.6.1 (on Page 17 of 23) states:

Worker access control is now automated because RP work processes have been computerized.

Please clarify whether there are active emergency Radiation Work Permits for use at all times in the event of emergency or are they required to be activated after an emergency classification.

Response

VY does not have Radiation Work Permits that must be activated after an emergency classification.

Instead, existing, active Radiation Work Permits are available at all times, including during an emergency.

An annual Radiation Work Permit dedicated for emergency plan response will be written and available on the first day of each year which will pre-authorize access for emergency response personnel in accordance with emergency plan implementing procedures. Site personnel will be notified of the Radiation Work Permit via site wide email and shift turnover as part of the annual reminder to review new Radiation Work Permits. No additional training will be necessary as use of Radiation Work Permits is addressed in radiation worker training.

BVY 14-054 / Attachment 1 / Page 8 of 12 RAI-VY-09 , Section 5.2.6.1 (on Page 17 of 23) states:

No RP involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight.

Please clarify whether these workers are trained to remove tools and/or equipment from the Radiologically Controlled Area or do they require RP support.

Response

The contamination monitoring activities described in the RAI are specific to personnel monitoring and monitoring of personal items and radiation workers are trained in these tasks. However, workers are not trained to remove tools and/or equipment from the RCA. Removing tools and/or equipment from the RCA would require monitoring by a qualified RP Technician as is currently required by station procedures.

RAI-VY-10 , Table 8.4 (on Page 1 of 2) states:

Onsite (out of plant) Shift RP Tech (1) on shift In plant surveys Shift RP Tech (1) on shift Based on the staff's review, it appears that there would be two RP technicians on-shift since there is no designation that these major tasks may be collateral duties. Please confirm that this conclusion is correct in regards to the number of on-shift RP technicians.

Response

VY's current on-shift staffing complement includes one (1) RP Technician. The post-shutdown on-shift staffing changes proposed in Reference 2 do not include any changes to the number of on-shift RP Technicians. The current On-Shift Staffing Analysis has concluded that the current on-shift staff is able to cope with the spectrum of analyzed events until augmenting ERO staff arrives.

Likewise, the analysis of the proposed post-shutdown on-shift staffing includes one (1) on-shift RP Technician. The analysis, developed to evaluate the ability of the proposed post-shutdown minimum on-shift staff to implement all emergency tasks, concludes that the proposed on-shift staff is able to cope with the spectrum of analyzed events in a permanently shutdown and defueled condition until augmenting ERO staff arrives.

Table B-1 of NUREG-0654 identifies the minimum staffing requirements for nuclear power plant emergencies. Table B-1 does not identify an on-shift position responsible for "onsite (out of plant)"

surveys. During the initial stages of an emergency, the on-shift RP Technician will be assigned to the most critical tasks during the emergency response. For consistency with Table B-1 of NUREG-0654, ENO proposes to delete the reference to the RP Technician "on-site (out of plant)" entry in SEP Table 8.4. VY maintains the capability to augment on-shift staff with field monitoring teams to

BVY 14-054 / Attachment 1 / Page 9 of 12 perform this task within 30 minutes of notification of an emergency declaration. Attachment 2 of this response provides the revised pages of the SEP with the proposed changes shown in strikethrough and underline format resulting from the change to Table 8.4 and the proposed change to the SEP is included in the Tabular Summary of Proposed Changes included as of this response.

RAI-MY-1 1 , Section 9.2.2.5 (on Page 83 of 125) states:

The EOF Manager establishes operations in the EOF/RC ...

However, Table 1 in Attachment 1 (on Page 7 of 23) indicates that this position is being eliminated. This position is also referenced in Attachment 3, Section 9.2.4 and numerous sections in the SEP that are not indicated in Attachment 3. Please clarify whether the EOF Manager position is being retained or eliminated, and provided appropriate supporting justification.

Response

The EOF Manager position is being eliminated. Attachment 2 of this response provides the revised pages of the SEP with the proposed changes shown in strikethrough and underline format resulting from the elimination of the EOF Manager position. The Tabular Summary of Proposed Changes to Site Emergency Plan, included as Attachment 2 to Reference 2, has been updated and is included as Attachment 3 of this response.

When operational, the EOF/RC assumes overall responsibility for the implementation of the emergency plan and serves as the near-site facility established to coordinate the activities of VY emergency response personnel; evaluate offsite accident conditions; and maintain coordination and communications with offsite response authorities. According to emergency planning procedure EPOP-EOF-3546, the EOF Manager is currently responsible for overseeing operations of the EOF/RC and assisting the Emergency Director in performance of key duties. Section 8.2.4 of the SEP currently describes the primary responsibilities of the EOF Manager as: 1) establish the EOF when required; 2) assess EOF habitability via the Radiological Assessment Coordinator; and 3) prepare the EOF for the arrival of offsite authorities and other support personnel. The duties of the EOF Manager are administrative in nature. The position has no role in accident assessment or mitigation activities and the position is not required to declare the facility operational.

The current ERO staffing required by the SEP and implementing procedures is intended to address the risks to public health and safety inherent in an operating reactor. As noted in Reference 2, ERO duties have been reviewed and duties for eliminated positions will be transferred to remaining ERO positions. Attachment 5 of Reference 2 provides the analysis of duties performed by the ERO, including the EOF Manager. Some of these duties are identified as being eliminated because they are already performed by other members of the ERO in the EOF and transfer of the responsibility is not necessary to ensure performance of the duty. The duties of the EOF Manager that are not currently performed redundantly by other ERO positions will not be eliminated, but will be transferred to the Emergency Director, Administration and Logistics Coordinator, EOF Technical

BVY 14-054 / Attachment 1 / Page 10 of 12 Advisor, Lead Off-Site Liaison or the Offsite Communicator in the EOF. Transfer of these duties is identified in Attachment 5 of Reference 2.

If additional resources are needed to support emergency response, the Emergency Director will assist or direct the Administration and Logistics Coordinator in obtaining additional resources.

RAI-VY-1 2 ,Section V.2 (on Page 12) states:

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

The staff is reviewing this application for proposed changes to on-shift staffing and 30/60 minute augmented responders, and not for the acceptability of a 90 minute augmented response. Please clarify the extent of changes being requested under ENO's license amendment.

Response

ENO is not requesting NRC review of any changes to the current 30/60 minute augmented response times. The statement included in Attachment 4, referenced, above, was provided for informational purposes only and documents an assumption used in the analysis.

RAI-VY-1 3 The staff's previous request for additional information, RAI-VY-01, based on our initial acceptability review, requested the following:

Please identify whether the proposed changes to the [Vermont Yankee Nuclear Power Station] VY SEP were evaluated for their impact with the State and local response organizations ability to effectively implement their [Federal Emergency Management Agency) FEMA-approved [radiological emergency preparedness]

REP plans, specifically in regards to licensee interface and coordination with State and local response organizations? If so, please provide evaluation performed and documentation regarding discussions with affected State and local response organizations used in making this determination.

In ENO's response dated May 21, 2014, it is not apparent to the staff that the State and local response organizations performed this review of their plan. ENO's response appears to indicate that ENO performed these evaluations. Please clarify whether the affected State and local response organizations independently performed the review of their affected plans and concur with the results provided in the ENO's response dated May 21, 2014, or if not, please identify the areas of issues and how these issues are resolved.

BVY 14-054 / Attachment 1 / Page 11 of 12

Response

An email was sent on June 17, 2014 to the appropriate emergency management officials from the states of Vermont, New Hampshire and Massachusetts requesting that they confirm that any needed changes to the State emergency response plans or procedures associated with the positions being eliminating from the ERO after the shutdown of VY have been identified and that the SEP changes still provide for adequate coordination and interface with the State emergency response organizations. By July 1, 2014, representatives from each State emergency management agency had replied that reviews of their radiological emergency response plans had been completed and that no additional changes to any of the plans were identified during this review.

RAI-VY-14 The staff's previous RAI (RAI-VY-02), based on our initial acceptability review, requested the following:

If potential impacts to OROs exist, have the proposed changes to the VY SEP been reviewed and agreed upon by the affected OROs to ensure they can continue to meet the requirements of their current FEMA-approved emergency plans? Please provide documentation that the affected OROs have reviewed and concurred on the proposed changes.

FEMA/NRC MOU [Memorandum of Understanding] establishes a "framework of cooperation" regarding the maintenance of REP programs to ensure continued reasonable assurance. Under the MOU, FEMA is responsible for determining the adequacy of offsite REP plans and preparedness and providing its findings to the NRC "to make radiological health and safety decisions in the issuance of licenses and the continued operation of licensed plants." The NRC will be providing the proposed changes to the facilities that have interface with the State and local response organizations to FEMA for their review.

ENO's response dated May 21, 2014, apparently did not address this request. Please provide documentation that the affected State and local response organizations are in agreement with the proposed changes, or if not, please identify the areas of issues and how these issues are resolved.

Response

As discussed in the response to RAI-VY-01 3, reviews of the proposed changes for impact on their radiological emergency response plans by representatives from the emergency management agencies from Vermont, New Hampshire and Massachusetts was documented by email exchange.

These emails have been provided to the NRC staff.

BVY 14-054 / Attachment 1 / Page 12 of 12 References

1. Letter, Entergy Nuclear Operations, Inc. to USNRC "Request for Approval of Certified Fuel Handler Training Program," BVY 13-095, dated October 31, 2013 (TAC No.

MF2998) (ADAMS Accession No. ML13325B015)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the Vermont Yankee Emergency Plan," BVY 14-018, dated March 24, 2014 (TAC No. MF3668)

(ADAMS Accession No. ML14085A257)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the Vermont Yankee Emergency Plan - Supplement 1 (TAC No. MF3668)," BVY 14-034, dated May 21, 2014 (ADAMS Accession No. ML14149A048)

BVY 14-054 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Revised SEP Pages

8.2.4. EOF-ManagefDeleted The EOF Marnager is a dsignated staff member of Vermont Yankee . anagement specifically trained to be responrSble for the fa*ility Eme=rgeRny Plan with respect to operation of the EOFiRCI. The EOF. Managers' primary respRnsibilities are to:-

1. Establish the Emergency Operations Facility when required;

2. Assess E~mergency Operations Facility habitability via the Radiological Assessment Coodinator;

3. Prepare the Emergency Operations Facility for the arrival of offsite authorities and otheFr SUPPrt persRnnel.

Emergency Operations Facility Manager at an AleF- oF higher emergency classification.

The EFQF Manager is responsible for repeoting to the E=mergency Director.

Emergency Plan Revision -54PENDING Page 53 of 125 Entergy Vermont Yankee

TABLE 8.3 (Continued)

(Page 2 of 3)

A

SUMMARY

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

Each State Health representative will review all factors and issue a final recommendation to the Directors of State Emergency management Agencies, who, in turn, will initiate response actions to implement this recommendation.

A coordination between the States will decide the time to implement the proposed actions, including activating the public alert and instructional methods (e.g., siren activation/NOA message, etc.)

Coordination of Radiological Data The Radiological Assessment Each State Health representative at Local communities rely on Coordinator is responsible for the EOF/RC will request monitoring State capability for radiological compiling offsite monitoring results updates from the FOQFManagef Lead evaluation.

and for ensuring an effective Offsite Liaison.

deployment of monitoring personnel as well as coordinating information In the State of Vermont, the Director of transfer. the Division of Occupational &

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

Emergency Plan Revision 54PENDING Page 62 of 125 Entergy Vermont Yankee

Table 8.4 (Page 1 of 2)

MINIMUM STAFFING REQUIREMENTS FOR THE ENVY ERO FUNCTIONAL MAJOR TASKS ENVY POSITION TITLE1 RESPONSE AREA TIME Plant Operations & Shift Manager (1) On Shift Assessment of CRS/Certified Fuel Handler (CFH).... (1) On Shift Operational Aspects OnQ-Shift AG-(6+AO/CRO/NCO*... (3) On Shift STA444 On Shift Emergency Direction Shift Manager (1**) On Shift

& Control (Emergency Coordinator)***

Notification / Notify Licensee, State .T.AO CRS/CFH On Shift Communication .. *. local and federal STA-Offsite Comm/ENS Comm/-eh-,T-eh4 30 min.

personnel & maintain (1) 3 60 min.

communication S-TAlOffsite Comm/ENS CommiGhe#rnTec-(2) 3 Radiological Emergency Operations EOF Emergency Director (1) 60 min.

Accident Facility (EOF) Director Shift MgrjCRS!CFH.ST.A.he. Tch On Shift Assessment and Offsite Dose assessment RP Staff (1)4 30 min.

Support of Operational Accident Off site surveys Field monitoring teams (2) 30 min.

Assessment Field monitoring teams (2) 60 min.

Onsite (out of plant) ShiftRPe GoW,-, ( i-Sh)

Field monitoring teams (1) 3 30 min.

Field monitoring teams (1) 60 min.

In plant surveys Shift RP Tech (1) On Shift RP staff (1) 30 min.

RP staff (1) 60 min.

Chemistry/ Shif Chem. Tech (1) On Shi#6O Radiochemistry Chem staff (1) min.

_ _ _60mmf4 Plant System Shift Technical Advisor Positions not needed in a Permanently GPS1qft Engineering Core/Thermal hydraulics Defueled ConditionS-TA)+44 .

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

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

Repair & Corrective Mechanical Maintenance Sb4-AOShift AO/CRO/NCO-1(I** On Shift Actions Mechanical Maintenance Maintenance (1) 60 min.

Rad Waste operator AOICRO(!AO/CROINCO 60 min.

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

Technician Maintenance (1) 60 min.

Instrumentation & Control Maintenance (1) 30 min.

Technician Emergency Plan Revision 54PENDING Page 64 of 125 Entergy Vermont Yankee

44-.12. The public information representative is notified and handles public information associated with the event; and 44-.13. The Shift Manager terminates the Notification of Unusual Event status and closes out the event with a verbal summary to offsite authorities or escalates to higher level emergency classification.

9.2.1.1. Unusual Event (Terminated) Response Ifa condition that warrants a Notification of Unusual Event declaration has occurred, and was immediately rectified such that the condition no longer existed by the time of declaration, this Notification of Unusual Event classification is referred to as an Unusual Event (Terminated).

The event or condition did not affect personnel onsite or the public offsite, Or result in radioactive releases requiring offsite monitoring.

The response to this declaration of an Unusual Event (Terminated) is not as comprehensive as that for a Notification of Unusual Event. All the same notifications for a Notification of Unusual Event are made, and emergency response personnel reporting to the plant are based on specific requests of the SM.

9.2.2. Alert Response An Alert requires actions to: 1) assure that sufficient emergency response personnel are mobilized to respond to the accident conditions at the site; and 2) that offsite emergency organizations are readily available to respond to the situation. Prompt notification is made to state officials and follow-up information is provided as needed to offsite emergency organizations. Unassigned personnel are evacuated from the site. In an Alert, the steps listed in the Notification of Unusual Event Response section (except for the termination process) and the following are performed:

1. The Alert emergency notification and response, as shown in Figure 9.1 and described in Table 9.1 are implemented;

2. The Technical Support Center, Operations Support Center, the Emergency Operations Facility/Recovery Center, and the Joint Information Center are activated by personnel as shown in Table 9.1;

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

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

5. The E©F-ManO.FeEmercency Director establishes operations in the EOF/RC; Emergency Plan Revision 54PENDING Page 83 of 125 Entergy Vermont Yankee

9.2.4. General Emergency Response All Emergency Centers are activated and all available resources are called upon in the event of a General Emergency. The plant promptly notifies offsite authorities and initiates all emergency response organization capabilities.

Offsite authorities fully activate their emergency response and implement appropriate protective measures based on meteorological information, actual or projected radiological dose conditions and/or conditions. The Emergency Director and the entire emergency response organization assemble plant status parameters and continually advise offsite authorities of the type of public protective action most appropriate to the situation based on plant conditions and offsite dose projections. This includes whether to shelter or evacuate the affected towns within the plume exposure emergency planning zone. In a General Emergency, the steps listed in the Site Area Emergency Response section and the following are performed:

1. The Emergency Director may request that the -- F*,F Manager mobilize other personnel be mobilized in support of Vermont Yankee through activation of the Corporate Emergency Center;

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

3. The full resources of the National Response Framework are activated; and

4. Dissemination of information and instructions associated with protective actions to the public is the principal focus of all response organizations. The plant fully participates in these efforts by providing detailed emergency condition information.

9.3. Emergency De-Escalation and Termination Criteria Classification of an accident condition requires that the plant operation staff recognize that pre-established EALs associated with an emergency condition, as defined in Appendix A, have been reached or exceeded.

De-escalation criteria require (1) an extensive review of plant parameters and/or offsite radiological conditions in conjunction with the pre-established EALs; (2) review of plant and offsite conditions with offsite authorities; and (3) concurrence by offsite authorities as to the appropriate time frame required to implement de-escalation.

Emergency Plan Revision 54PENDING Page 85 of 125 Entergy Vermont Yankee

BVY 14-054 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Updated Tabular Summary of Proposed Changes to SEP

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

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

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

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

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

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

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

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

Section 4.1 Vermont Yankee Nuclear Power Station Vermont Yankee Nuclear Power Station VY will no longer be an operating is located on the west bank of the is located on the west bank of the nuclear power plant. The Site Connecticut River immediately Connecticut River immediately Description has been revised to upstream of the Vernon Hydrostation, upstream of the Vernon Hydrostation, indicate the permanently shutdown in the town of Vernon, Vermont. The in the town of Vernon, Vermont. The 1 of 21

Emergency Plan Section Before (Rev. 54) After [ Reason for Change Vermont Yankee Nuclear Power Station Vermont Yankee Nuclear Power Station and defueled condition.

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

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

With irradiated fuel being stored in the Spent Fuel Pool and the ISFSl, the 2 of 21

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

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

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

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

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

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

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

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

3 of 21

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

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

• Shift Technical Advisor (STA)

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

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

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

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

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

These staffing levels have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently 4 of 21

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

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

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

• Operations 0 Operations

• Maintenance 0 Maintenance

• Reactor Engineering

• Engineering

• Engineering 0 Chemistry

• Chemistry (in the OSC) 0 Radiation Protection

• Radiation Protection 0 Security (stationed at the off

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

Section 8.2.4 EOF Manager Deleted entire section The EOF Manager position will not exist in the Permanently Defueled ERO. Duties and responsibilities will be transferred to remaining positions within the EOF.

5 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.3, Page 2 of 3 Each State Health representative at the Each State Health representative at the The EOF Manager position will not EOF/RC will request monitoring EOF/RC will request monitoring exist in the Permanently Defueled updates from the EOF Manager. updates from the Lead Offsite Liaison. ERO. Duties and responsibilities will be transferred to remaining positions within the EOF.

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

Duties and responsibilities will be transferred to the Technical Advisor position.

Table 8.4 - Page 1 of 2, Functional ,'fl) Ion shift I Shift On Sift VY will wi**no longer be an operating Area - Plant Operations & CRS i1. On Shift CRSCerifiedFuel Handler (CFH.(1) I On Sh,,t nuclear power plant. The following

'RO i2i On Sh1f0 i AO1CRO.NCO' "3 OS os nw Assessment of Operational Aspects AO!6l O on-shift positions will be STA (1I On Shift eliminated:

• STA

" Two (2) Control Room Operators

• Three (3) Auxiliary Operators

" Chemistry Technician Following permanent cessation of operations and removal of fuel from the reactor vessel, Operations on-shift personnel will consist of the SM, one (1) CRS/ CFH and three (3) AOs/CROs/NCOs. Title changes for the CRS to CFH and AO and CRO to NCO are dependent upon NRC approval of proposed changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with 6 of 21

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

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

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

Table 8.4 - Page 1 of 2; Functional SlAiAo on ShiOt CR;CFH VY will no longer be an operating Area - fl*!ENS STAgOflsiie Popj iCtminJEHS 30 rain oiffsi:eCommiEt.SCommnnh 3Onuiin nuclear power plant. The STA Notification/Communication; i

• Offs*I, e miQi offsi comm;EttS Comm(2r Lo.m position will be eliminated.

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

STA assignments in this functional area will be transferred to a CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated 7 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change accidents that will be applicable in the permanently defueled condition.

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

Table 8.4 - Page I of 2; Functional EOF Emrgency D,,eo, i 60 m EOF Emergetc Director il) sn 60 VY will no longer be an operating Area - Radiological Accident shift gý,1.CRSIST*ct*V*. O Sf- Shft . CRSCFH On Shift nuclear power plant. The STA and Assessment and Support of R Staff W 30 on-shift Chemistry Tech positions Operational Accident Assessment; will be eliminated.

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

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

8 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4 - Page 1 of 2; Functional  :

.......... ... ..................-........ _;" This change doesmnot1represent does not represent a Area - Radiological Accident Shit RP tech~ i Fieldmonilonng eamsn(1 (I ------- --- - 6n_ hift 30 min.

!FeLrimontnntams ()

30mm mln 4 This change to thenumberofon-shifta chonge Assessment and Support of Feldnonitormnteams1) 60

• RP Technicians. The number of on-Operational Accident Assessment; shift RP Technicians remains one Maior Tasks - Onsite (out of plant) (1). The change is intended to clarify VY's RP Technician duties during an emergency, consistent with Table B-1 of NUREG-0654.

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

Table 8.4- Page 1 of 2; Functional Shift Chem Tech it! On ShIft I emsar(i*I VY will no longer be an operating Area - Radiological Accident Chem st1 60 I nuclear power plant. The on-shift Assessment and Support of Chemistry Tech position will be Operational Accident Assessment; eliminated.

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

9 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4- Page 1 of 2; Functional To I Shift Po P ,ni~o-n.e.c.d

. ..ed . '.. e n ...-. .... . VY will no longer be an operating Area - Plant System Engineering; TSC RE *[ 30 mmi P flCo.dlroa nO eso' led " nuclear power plant. The STA Major Tasks - Shift Technical position will be eliminated.

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

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

Table 8.4 - Page 1 of 2; Functional The Defueled Organization contains Shift AO il'i CiSt Shift ACGRO.NCO(1") onShift Area - Repair & Corrective Actions; three (3) AOs/CROs/NCOs on-shift.

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

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

10 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4 - Page I of 2; Functional The CRO position is eliminated in Area - Repair & Corrective Actions; -OCRO .*i 60 mi AC',RONCO Om, the post-shutdown condition. The Major Tasks - Rad Waste Operator Defueled Organization consists of three (3) AOs/CROs/NCOs on-shift.

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

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

Table 8.4- Page 1 of 2; Functional n.i. oO Sh'fAOCR*ONC0i o -- The Defueled Organization consists Area - Repair & Corrective Actions; ,,in.enw.ce fl 30 ... Maintenance (1) 30 min of three (3) AOs/CROs/NCOs on-Major Tasks - Electrical .Annnnce

.. 60mm. Maintenance ) I.

6.m shift. This on-shift complement has Maintenance/Instrumentation & been evaluated in the VY analysis Control Technician of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

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

11 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4 - Page 2 of 2; Functional shift AO i2.. : On Shift Shift AO'CRO'NC0,2"): On Shf The Defueled Organization consists Area - Protective Actions (In Plant); RP iý2 30 m*n RP 2) 30 ,* of three (3) AOs/CROs/NCOs on-on i2 60mC (3 RP 2) 6o min, Major Tasks - Radiation Protection, shift. This on-shift complement has access control, HP, coverage for been evaluated in the VY analysis repair, corrective actions, search & of proposed post-shutdown on-rescue, first aid & firefighting, shift staffing in conjunction with personnel monitoring, dosimetry the postulated accidents that will be applicable in the permanently defueled condition.

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

Table 8.4, Note

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

typically associated with those Title changes for the CRS to CFH performed by Auxiliary Operators and and AO and CR0 to NCO are Control Room Operators, such as dependent upon NRC approval of manipulation and monitoring of plant proposed changes to the VY equipment. Technical Specifications that 12 of 21

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

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

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

dated 4/14/1981 (FVY 81-65) establishing position. VY letter to NRC 6/22/1982 (FVY 82-75) Supplement-NUREG 0737 Item III.A.1.2 on training of on-shift staff to support VY position for staffing. VY letter to NRC 4/14/1981 (FVY 81-65) TMI Action Plan Item III.A.1.2, goal for augmentation of staff. VY letter to NRC 6/15/82 (FVY 82-70) Results of Augmentation drills to support use of goals. Titles of ENVY ERO positions are shown.

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

Table 8.4, Note 3 ENVY has designated pager holders ENVY has designated ERO members The Defueled Organization will who staff positions required to meet who staff positions required to meet consist of fewer than 4 teams 13 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change minimum staffing to activate TSC, OSC minimum staffing to activate the TSC, rotating ERO duty.

and EOF (see E Plan Figures 8.3 through OSC and EOF. The minimum staff Additional changes to this note are 8.5). There are a minimum of 4 positions required to activate the TSC persons per position (4 teams who and EOF are shown in E Plan Figures 8.3 editrial to r ovrers t rotate duty). However, all persons on and 8.5. The OSC Manager is the only teams are expected to respond. In position required to activate and staff addition, all other ERO personnel not the OSC. All ERO personnel are on pagers are notified by the expected to respond when notified by emergency call-in notification system the emergency call-in notification and are expected to respond. system.

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

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

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

• Shift Technical Advisor

• STA

• Chem Tech C Two (2) Control Room

• Control Room Operators Operators Replaced "Auxiliary Operators" with 0 Three (3) Auxiliary Operators "AOs/CROs/NCOs" 0 Chemistry Technician Following permanent cessation of operations and removal of fuel

• from the reactor vessel, Operations on-shift personnel will consist of the (SM, one (1) CRS/ CFH and three (3) AOs/CROs/NCOs. Title changes for the CRS to CFH and AO and CRO to NCO are dependent upon NRC approval of proposed 14 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change changes to the VY Technical Specifications that replace references to licensed and non-licensed operators with references to CFHs and NCOs.

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

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

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

" EOF Manager transferred to remaining positions

" TSC Manager within each Emergency Response Facility.

Figure 8.3 Technical Support Center Emergency Replaced figure with "Defueled The TSC positions identified for Organization Technical Support Center Emergency deletion will not exist in the Organization" Permanently Defueled ERO. Duties Deleted the following positions: and responsibilities will be 15 of 21

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

" TSC Manager transferred to remaining positions

" TSC Communicator within the TSC.

" Mechanical Engineer

• Reactor Engineer

• Electrical /I&C Engineers

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

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

• EOF Manager within the EOF.

• EOF Communicator

" Public Information Liaison

• EOF Log Keeper

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

" Information Coordinator transferred to remaining positions

• Technical Assistant within the JIC.

• Credentialing

• Press Release Writer

" Logistics Coordinator

" Inquiry Response Coordinator

• Media Monitoring

• JIC Log Keeper 16 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change 0 Inquiry Responders Section 9.2.1 - 2 nd Paragraph 3. The Shift Technical Advisor reports Deleted VY will no longer be an operating to the Control Room and provides nuclear power plant. The STA technical support as necessary; position will be eliminated.

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

Section 9.2.2 5. The EOF Manager establishes 5. The Emergency Director The EOF Manager position will not operations in the EOF/RC; establishes operations in the exist in the Permanently Defueled EOF/RC: ERO. Duties and responsibilities will be transferred to remaining positions within the EOF.

Section 9.2.4 - 2nd Paragraph 1. The Emergency Director may 1. The Emergency Director may The EOF Manager position will not request that the EOF Manager request that other personnel be exist in the Permanently Defueled mobilize other personnel in mobilized in support of Vermont ERO. Duties and responsibilities will support of Vermont Yankee Yankee through activation of the be transferred to remaining through activation of the Corporate Emergency Center. positions within the EOF.

Corporate Emergency Center.

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

1. Criticality controls are in effect; 1. Criticality controls are in effect; the ne a u ate core cooi, the need for adequate core cooling,

2. The core is being adequately 2. The fission product release has control over containment pressure cooled; been controlled; and temperature and control of reactor coolant system pressure is 17 of 21

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

3. The fission product release has 3. An adequate heat transfer path to not necessary.

been controlled; an ultimate heat sink has been established; over

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

5. An adequate heat transfer path to are under control, and are not an ultimate heat sink has been expected to deteriorate further.

established;

6. Reactor coolant system pressure is under control; and/or

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

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

Reactor Engineer System, Design)

Engineering Coordinator(Project, Operations Coordinator System, Design)

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

The OSC positions identified for 18 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Spare Licensed Operators Spare AOs/CROs/NCOs deletion will not exist in the Spare Auxiliary Operators Control Instrument Specialists Permanently Defueled ERO. Duties and responsibilities will be Control Instrument Specialists Plant Mechanics transferred to remaining positions within the OSC.

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

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

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

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

19 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change in charge of the emergency response the general public be advised to seek activities, recommends that the general shelter for the towns of Hinsdale, New public be advised to seek shelter for Hampshire and Vernon, Vermont; and the towns of Hinsdale, New Hampshire the towns located five miles downwind and Vernon, Vermont; and the towns in the affected sectors.

located five miles downwind in the affected sectors.

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

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

Environmental Protection Agency Environmental Protection Agency Emergency Worker Dose Limit Guides Emergency Worker Dose Limit Guides (EPA 400-R-92-001). The Shift Manager (EPA 400-R-92-001). The Shift Manager initially has the responsibility to initially has the responsibility to authorize emergency dose authorize emergency dose commitments until relieved by the commitments until relieved by the Emergency Plant Manager. This Emergency Plant Manager. This authorization is coordinated with the authorization is coordinated with the assistance of the Radiological assistance of the Radiological Coordinator or Shift Chemistry and Coordinator and Radiation Protection Radiation Protection Technicians as Technicians as needed. Exposure to needed. Exposure to individuals individuals providing emergency providing emergency functions will be functions will be consistent with the consistent with the limits specified in limits specified in Table 10.2 with every 20 of 21

Emergency Plan Section Before (Rev. 54) After Reason for Change Table 10.2 with every attempt made to attempt made to keep exposures keep exposures ALARA. ALARA.

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

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

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