ML15076A074

Emergency Plan Change, Revision 55

ML15076A074
Person / Time
Site:	Vermont Yankee
Issue date:	02/23/2015
From:	McKenney M P Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 15-003, TAC MF3668
Download: ML15076A074 (248)

Text

f Entergy Entergy Nuclear Operations, Inc.Vermont Yankee P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 258 4183 Michael P. McKenney Emergency Planning Manager BVY 15-003 February 23, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

REFERENCE:

Emergency Plan Change, Revision 55 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28 Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station -Issuance of Amendment to Renewed Facility Operating License RE: Changes to the Emergency Plan (TAC NO.MF3668,)" dated February 4, 2015

Dear Sir or Madam:

In accordance with 10 CFR 50.54(q) Entergy Nuclear Operations, Inc. is providing Revision 55 of the Vermont Yankee Nuclear Power Station Emergency Plan (Plan) as an attachment to this letter. This revision of the Plan incorporates changes approved by the NRC in Reference

1. This revision also includes several changes that were evaluated pursuant to 10 CFR 50.54(q)(3) that were determined not to require prior NRC approval.

Included with this revision is a description of the changes and the 10 CFR 50.54(q) Screening and Evaluation Forms for those changes performed pursuant to 10 CFR 50.54(q)(3).

There are no new regulatory commitments contained in this submittal.

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

Sincerely, MPM/jha BVY 15-003/ Page 2 of 2

Attachment:

Emergency Plan Change, Revision 55 cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd.Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street -Drawer 20 Montpelier, Vermont 05620-2601 BVY 15-003 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Emergency Plan Change, Revision 55 EMERGENCY PLAN ENTERGY VERMONT YANKEE VERNON, VERMONT REVISION 55 PREPARER: REVIEWED: APPROVED: APPROVED:-MP McKenney 0 of 0 :91 Z. z2zzýr EmergenWP4annIn a er nt/Sign) Date Oý-Site Sifetypoýý mm e (Print/Sign)

Aate M icha e l R o m eo ' ' 1: 1 --. 1 , General Mal gn)Chris WaVmser P0 t we_- -Site Vibe Presildt (Print/Sign)

Date Date Effective Date 02/05/15 ENTERGY VERMONT YANKEE EMERGENCY PLAN REVISION

SUMMARY

DATE REVISION DESCRIPTION 04/28/04 39 Replaced Framatome ANS services and the DE&S Mutual Assistance Agreement with the Corporate Service Center from White Plains.Updated information about the NAS to the new NAS system that was installed.

Added Mechanical Maintenance to the Repair & Corrective Actions section for the 60 min. response in Table 8-4. Removed the EOFC Asst. and Communications positions.

Removed requirement for drills to include a PASS sample.03/15/05 40 Removed references to satellite phones. Revised Figures 7.1 and 7.2.Updated Evacuation Time Estimate (Appendix F) based on study conducted in 2004. Updated Table 4.2 and Figures 4.3, 4.4 and 4.5 based on 2000 census data per UFSAR Rev. 19. Updated Section 4.2 for latest population figures per UFSAR Rev. 19. Joint News Center activation changed from SAE to Alert. Removed references to"typically filled by" titles and "designated alternates" due to change to four teams. Deleted Table 8.1. Changed alternate Joint News Center location from Marlborough, MA to Landmark College. Revised Figure 6.3 for new OSC Communication Center location.

Revised Figure 6.4 for new EOF/RC Center Layout. Section 8.2.1 SRM responsibilities revised. Section 8.2.2 TSC Coordinator responsibilities revised. Security Coordinator position reports to off site command center instead of the TSC. Revised Figure 8.3.Removed requirement for TS Coordinator to appoint an OSC Coordinator due to four team assignments.

Revised Section 9.0 to require activation of the Joint News Center at the Alert. Revised Table 9.1. Updated Appendix E with recent letters of agreement from DOE/REAC and INPO. Deleted letters of agreement with Duke Engineering

& Services for old alternate joint news center and Yankee Rowe for lab sample analysis and decontamination services.

Updated Appendix G with new procedures AP 3549 and OP 3550. Removed reference to JNC Guidelines which were replaced by OP 3550.Changed OP 3505 to AP 3505 and OP 3712 to AP 3712. Deleted Section 8.2.7 Radiological Coordinator.

Section 8.2.6 revised Rad Assistant responsibilities.

Revised Table 8.4 to remove reference to Radiological Coordinator.

Revised Figure 8.2 to delete Radiological Coordinator.

Revised Figure 8.5 to delete Radiological Coordinator and communicators.

Replaced with Radio Operator and RP staff.Revised Figure 8.7 to reflect changes due to four team rotation.Emergency Plan Revision 55 Revision Summary Page i of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 01/18/06 41 Incorporated changes per NRC Bulletin 2005-02 (ECL definition changes, Security drills, Hostile Action definitions).

Changed "Unusual Event" to "Notification of Unusual Event" to conform to industry standards.

Changed title -Director of Public Affairs to Manager of Communications.

Changed reference from Plant Operations Review Committee to On-Site Safety Review Committee.

Letters of agreement reviewed annually in conjunction with annual review of the E-Plan. Updated respiratory protection locations per RP changes.Updated letters of agreement for States, DOE-REAC/TS and Vernon Fire Department.

Added letters of agreement for States regarding Alert & Notification System (ANS). Added OP 3548 and OP 3551 to list of Implementing Procedures in Appendix G. Updated Appendix H for the implementation of the new siren system.06/22/06 42 Corrected Hostile Force definition

-"overtly" had been omitted from the last revision (WT-VTY-2006-00000 CA#00463).

Revised thermal rated power per License Amendment

1. 229, issued March 2, 2006 (CR-VTYLO-2006-0004 CA#23). Removed reference to gross electrical output. Per Regulatory Information Summary 2003-18, Supplement 2, issued December 12, 2005, removed the requirement for states to concur with changes to the Emergency Action Levels.Changed TLD (thermoluminescent device) references to DLR (dosimeter of legal record) per Radiation Protection change. Replaced the annual INPO letter of agreement with the latest version. Updated the general letters of agreement with Vermont and New Hampshire.

Added memorandum of understanding for Alert & Notification System with Vermont and New Hampshire.

Added new procedure, OP 3552, Activation and Operation of the Alternate Joint News Center.Emergency Plan Revision 55 Revision Summary Page ii of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 10/10/07 43 Changed TLD (thermoluminescent device) references to DLR (dosimeter of legal record) per Radiation Protection change. Replaced the annual INPO letter with the latest version. Updated the general letters of agreement with Franklin Medical Center, Brattleboro Memorial Hospital, Rescue, Inc. Ambulance Service, Vernon Fire Department, Brattleboro Fire Department, Vermont Yankee Nuclear Power Corporation.

Appendix G -added new procedures, AP 3553, Administration and Maintenance of the Alert and Notification System, and AP 3554, Emergency Plan Teams; deleted references to procedures OP 3524, OP 3525 and OP 3531 which were incorporated into other procedures; added EN-EP-605, Corporate Incident Response Team. Changed Joint News Center to Joint Information Center throughout.

Changed Figure 6.1 to reflect new location of Massachusetts Region III EOC. Revised Figure 6.3 to remove reference to the medical office and update Control Point personnel contamination monitor label. Changed reference from Vermont Operational Quality Assurance Manual to Entergy Quality Assurance Manual. Removed references to the Duty On Call Officer. Removed requirement for Plant Certification for the TSC Coordinator.

Changed references to "corporate-level" to reflect Entergy organization.

Revised EOF Coordinator and Radiological Assistant responsibilities to reflect organizational changes. Changed "onsite assistance teams" to "repair and corrective action teams." Revised Figure 8.5 to indicate that the EOF Coordinator is not needed for activation of the EOF.Removed references that required the TSC Coordinator to respond at the Notification of Unusual Event level and revised the responsibility to direct and coordinate all emergency response efforts. Revised Table 9.1 to reflect changes in the emergency response organization structure.

Removed respiratory protection from the equipment inventory for the EOF. Revised "Emergency Broadcast Stations" to"Emergency Alert System stations." Removed reference to the Engineering Support Group as a separate entity. The Engineering Support Group is part of the TSC. Fire Brigade Leader changed from Shift Technical Advisor to Field Support Supervisor on Table 8.4.Removed specific number of federal agencies available.

Revised the reference to the TSC capacity.

Revised the OSC Coordinator location to direct the OSC. Removed "designee" to the SRM responsibility to approve press releases.

Removed switchboard from the EOF.Removed NID Assistant from the JIC. Revised Table 9.1 to reflect ERO structure.

Added the use of State Reception Center for decontamination efforts.Emergency Plan Revision 55 Revision Summary Page iii of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

DATE REVISION DESCRIPTION 02/06/08 44 Implementation of the Independent Spent Fuel Storage Installation (ISFSI). Include ISFSI Emergency Action Level (EAL) for Notification of Unusual Event. Include definitions for ISFSI and Confinement Boundary.

Update sections, tables and figures for title changes due to fleet alignment.

Facility activation procedures incorporated into facility operation procedures.

08/21/08 45 Implementation of the fleet standard Emergency Response Organization (ERO). Joint Information Center relocation.

03/12/09 46 Reference to Federal Radiological Emergency Response Plan (FRERP) changed to National Response Framework (NRF). Editorial changes. Rearrange OSC and EOF layouts. Annual Update of Letters of Agreement

-no content change. Additional sirens added to Appendix H. Add FVY reference numbers to letters cited in Table 8.4 Note 1.12/15/09 47 Revised Section 5.0 to indicate that the revised Emergency Action Levels are based on NUMARC/NESP-007 (NEI 99-01), "Methodology for Development of Emergency Action Levels", Rev. 5, dated February 2008. Revised 6.2.3, Meteorological Capability, to reflect the as-built elevations for the temperature instruments.

Deleted reference to the UHF radio antennas being mounted on the primary meteorological tower in Section 7.3. Changed "Federal Radiological Emergency Response Plan" to "National Response Framework" on Figure 9.1.Revised paragraph 5 of Section 12.1.2, Communications Tests, to indicate the monthly NRC communications test is with the Headquarters Operations Officer rather than the NRC Region I Office.Replaced the AP 3125 EAL Chart with the revised EAL charts in Appendix A. Replaced AP 3505, Emergency Preparedness Exercises and Drills, with fleet procedures EN-EP-306, Drills and Exercises, and EN-EP-307, Threat Based Drills, in Appendix G. Corrected siren numbers on the Siren List in Appendix H. Added the siren drawing for the Bernardston sirens in Appendix H.03/30/10 48 Revised Figure 4.1 to add the Vernon Substation.

10/21/10 49 Revised Table 8.4: Added STA (1) to Plant Operations

& Assessment of Operational Aspects functional area section. This change is being instituted to clarify specific coverage detail. Deleted the verbiage that specifies who the fire brigade consists of (FSS, 3 AO, and 1 Security)from the Fire Fighting functional area section. Added an (*) with comment that "Position staffed in accordance with Technical Requirements Manual and administrative procedures".

The change is being instituted to be consistent with the TRM and to simplify upkeep of the Emergency Plan document.Emergency Plan Revision 55 Revision Summary Page iv of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

DATE 04/28/11 REVISION DESCRIPTION 50 Updated figure 6.4 to reflect changes in the EOF facility arrangement.

Updated section 6.2.6, 10.1.3, 10.3, Appendix B and Appendix D to reflect current capabilities for outside analytical assistance and laboratory facilities support. Updated letters of agreement for: State of Massachusetts, State of New Hampshire, State of Vermont, Vernon Fire Department, Brattleboro Fire Department, and Institute of Nuclear Power Operations.

Updated memorandum of understanding for State of Massachusetts Alert & Notification System, State of New Hampshire Alert & Notification System, and State of Vermont Alert & Notification System.Emergency Plan Revision 55 Revision Summary Page v of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

Section 3.2: Actions in an Emergency, Step 7 5/24/12 51 Step 7 was revised from "Use the plant pager system to notify appropriate personnel...

to "use the emergency notification system to notify appropriate personnel...

Section 6.1.3: Emergency Operations FacilitylRecovery Center Added a statement to address ERO Augmentation at Alternate Facilities Section 8.4.1, Local Service An editorial ct ange was made to this section to add Baystate to the name of Franklin Medical Center Table 8.4, Mir imum Staffing Requirements for the ENVY ERO Table 8.4 has I ieen updated to replace Security with the Fire Brigade for the functional area of "Rescu 3 Operations

& First Aid", Changed Rad Waste Operator from ACRO to CRO Section 9.1 Em .rgency Condition Recognition and Classification Added a to address Emergency Declaration Timeliness Section 9.2.4 Goneral Emergency Response, Step I This section was updated to refer to the Corporate Emergency Center located in Jackson MS for tne EOF Manager to contact in a General Emergency for fleet support.Figure 9.1, Notifioation Plan Figure 9.1 notification plan has been updated to align with the implementation of Everbridge and OF' 3540, (Control Room Actions During an Emergency) and show operations as the initiator of the notifications Section 10.4.4, Usa of Onsite Protective Equipment and Supplies Editorial change to correct Iodine to Iodide.Section 10.6, Protective Actions for Onsite Personnel Added a statement for Protective Actions for Onsite Personnel Section 12.1.2, Com rnunication Tests Section 12.1.2 has been updated to align with the Everbridge implementation at Vermont Yankee and evise the wording for the weekly communication test.Appendix E -Letters of Agreement Updated the follc wing letters (18 is newly added)o Letteo 4, Baystate Franklin Medical Center o Lette; 5, National Weather Service (NOAA)o Letter 6, Brattleboro Memorial Hospital o Letter 7, Rescue Inc Ambulance Service o Letter 10, Institute of Nuclear Power Operations o Letter 11, Town of Vernon o Letter -2, DOE o Letter 13, DOE-REAC/TS o Letter 14, Vermont Yankee Nuclear Power Corporation o Letter 1t3, Landmark College Appendix G -Index of Emergency Plan Implementing Procedures and Support Plans o Emergency Plan Implementing Procedures o Support Plans o Corporate Support Procedures Emergency Plan Revision 55 Revision Summary Page vi of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

Section 7.9 "Emergency Response Data System" Removed 12/20/12 52 wording regarding activation within one hour of an alert and replaced it with a statement for maintaining a continuous connection Section 8.1 "Normal Plant Organization" Updated the on shift staffing to include one (1) FSS, five (5) AOs, and one (1) Utility employee per the Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis Section 8.2.3 "Shift Manager" Updated the last sentence of the paragraph to state "The immediate responsibilities of the Shift Manager include performing or delegating performance of the following." Table 8.4 "Minimum Staffing Requirements for the ENVY ERO" Replaced SCRO with CRS in the Table and on note 4. Title change only.* Updated AOs from 3 to 5* Added 1 FSS* Added FSS to offsite dose assessment

• Note 1: Added a reference to the Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis for composition of the 5 person fire brigade* Note 4: Added FSS for performing initial dose assessment Appendix A "Emergency Classification System and Emergency Action Levels" -Added a cross reference to AP 3125, "Emergency Plan Classification and Action Level Scheme" for EAL Charts and removed the image of the EAL Chart Appendix G "Index of Emergency Plan Implementing Procedures and Support Plans"* I1. Support Plans- Added Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis 0 Corporate Support Plans: Added procedure EN-EP-302"Severe Weather Response" effective 11/5/12 Emergency Plan Revision 55 Revision Summary Page vii of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

Section 8.1, Normal Plant Organization 9/17/13 53 9 Updated AOs from 5 to 6* Deleted Utility person Table 8.4, Minimum Staffing Requirements for the ENVY ERO" Plant Operations

& Assessment of Operational Aspects -Updated AOs from 5 to 6* Fire Fighting -Added the total number (5); Added ** to reference the note "May be provided by shift personnel assigned other functions" and added reference to note 1 regarding the Fire Brigade being staffed lAW TRM, Staffing Analysis and AP 0894.Figure 8.1 -Corrected the number on on shift AOs and added the Field Support Supervisor (FSS)Appendix E, Letters of Agreement* Updated INPO letter for 2012* DOE -REAC/TS -Updated letter dated June 6, 2013. The letter content remains unchanged.

• Deleted letter 14 "Vermont Yankee Nuclear Power Corporation" no longer valid as of 12/31/12 Appendix G, Index of Emergency Plan Implementing Procedures and Support Plans* Added Fleet Administrative Procedure references

• Updated procedure references in accordance with the procedure upgrade project numbering scheme Emergency Plan Revision 55 Revision Summary Page viii of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

Index 12/19/13 54* Added 7.1 InForm Notification System 3.2. Actions in an Emergency* Changed Nuclear Alert System to Emergency Notification System in step 5 for notifying the three states 6.2.6. Facilities and Equipment for Offsite Monitoring

• Removed the reference to the James A. Fitzpatrick environmental laboratory

7.1. InForm

Notification System* Added a description for the InForm Notification System 7.2. Nuclear Alert System* Changed the words "Is used" to "can be" used to describe the Nuclear Alert System Figure 7.1, Plant to State Notification Channels* Added a line for Inform Figure 7.2, Coordination Channels with States" Added a line for Inform Section 8.1. Normal Plant Organization

• Removed the Field Support Supervisor from the Normal Plant Organization Table 8.4. Minimum Staffing Requirements for the ENVY ERO" Notification/Communication:

changed Chem Tech to AO" Radiological Accident Assessment

-Deleted Field Support Supervisor (FSS) and added Chem Tech." Note 4 -Deleted FSS and added Chem Tech Figure 8.1. Normal On-Shift Emergency Organization

• Revised to match shift staffing in section 8.1 and remove the Field Support Supervisor (FSS)Figure 9.1. Notification Plan* Changed NAS to Inform/NAS Appendix E, Letters of Agreement* Letters of Agreement have been removed from this document and will be maintained in the Emergency Plan Department files. A summary of the agreements has also been added.Appendix F, Evacuation Time Estimates* An evacuation time estimate summary has been removed from this document and the entire document is maintained separately and referenced in this appendix.Appendix G, Index of Emergency Plan Implementing Procedures and Support Plans* Updated procedure numbers to match the procedure upgrade project numbering* Added the Evacuation Time Estimate to Support Plans Emergency Plan Revision 55 Revision Summary Page ix of x Entergy Vermont Yankee REVISION

SUMMARY

(Continued)

Date Pending Refer to Change Summary identifying Emergency Plan changes associated with NRC approval of BVY 14-018 and additional post-shutdown Emergency Plan changes evaluated via 50.54(q).Emergency Plan Revision 55 Revision Summary Page x of x Entergy Vermont Yankee TABLE OF CONTENTS 1.0 INTRO DUCTIO N ........................................................................................................

1 2.0 DEFINITIO NS .............................................................................................................

2 3.0 SUM MARY OF EM ERG ENCY PLA N ...................................................................

6 3.1. Objectives

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

6 3.2. Actions In An Em ergency ...........................................................................

7 3.3. Em ergency Response Facilities

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

7 3.4. Mobilization

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

8 3.5. State Government Notification and Response ............................................

8 3.6. Federal Governm ent Notification and Response ........................................

9 3.7. Technical Support ......................................................................................

9 4.0 THE AREA ...............................................................................................................

10 4.1. The Site ...................................................................................................

10 4.2. Area Characteristics, Land Use and Dem ography ....................................

10 4.3. Em ergency Planning Zones ......................................................................

12 5.0 EMERGENCY CLASSIFICATION SYSTEM ......................................................

25 5.1. Notification of Unusual Event ....................................................................

25 5.1.1. Unusual Event (Term inated) ....................................................

26 5.2. Alert ...............................................................................................................

26 5.3. Site Area Em ergency ...............................................................................

26 5.4. General Em ergency .................................................................................

27 5.5. Emergency Classification System Review by State Authorities

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

27 6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT

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

28 6.1. Em ergency Response Facilities

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

28 6.1.1. Technical Support Center ........................................................

28 6.1.2. The Operations Support Center ................................................

29 6.1.3. Emergency Operations Facility/Recovery Center ......................

30 6.1.4. Deleted ......................................................................................

31 6.1.5. Joint Inform ation Center ..........................................................

31 6.1.6. Coordination of Radiological Data ............................................

31 6.2. Assessm ent Capability

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

32 6.2.1. Process M onitors ......................................................................

32 6.2.2. Radiological M onitors ...............................................................

32 6.2.3. Meteorological Capability

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

33 6.2.4. Fire Detection Devices .............................................................

34 6.2.5. Post-Accident Sam pling ...........................................................

34 6.2.6. Facilities and Equipm ent for Offsite M onitoring

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

34 7.0 COM M UNICATIO NS ...........................................................................................

40 7.1. InForm Notification System ......................................................................

40 Emergency Plan Revision 55 Table of Contents Page i of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

7.2. Nuclear

Alert System ...............................................................................

40 7.3. Utility Microwave and Radio Systems ......................................................

41 7.4. Mobile UHF Radio System .........................................................................

41 7.5. Plant Intercom System .............................................................................

41 7.6. NRC Telephone System ..........................................................................

41 7.7. Commercial Telephone System ...............................................................

42 7.8. Emergency Power Supply for Communications

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

42 7.9. Facsimile Transmission

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

42 7 .10 .C e leted ...................................................................................................

..4 3 8.0 ORGANZATION

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

47 8.1. Normal Plant Organization

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

47 8.2. Emergency Response Organization

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

47 8.2.1. Emergency Director ..................................................................

49 8.2.2. Emergency Plant Manager ......................................................

50 8.2.3. S hift M anager ..........................................................................

51 8 .2 .4 .D e leted ....................................................................................

..5 1 8.2.5.. Operations Support Center Manager .........................................

52 8.2.6 Radiological Assessment Coordinator

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

53 8.2.7. Administration and Logistics Coordinator

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

54 8.2.8. Security Coordinator

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

54 8.2.9. Company Spokesperson

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

55 8.2.10. Decision Maker ........................................................................

55 8.2.11. Engineering Support Group ......................................................

55 8.3. Recovery Organization

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

56 8.4. Extensions of Vermont Yankee Emergency Organization

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

57 8.4.1. Local Service .............................................................................

57 8.4.2. Federal Government Support ...................................................

57 8.4.3. Additional Support ...................................................................

58 8.5. Coordination with State Government Authorities

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

58 9.0 EMERGENCY R=ESPONSE

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

69 9.1. Emergenc', Condition Recognition and Classification

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

69 9.2. Activation of the Emergency Organization

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

69 9.2.1. NIotification of Unusual Event Response ...................................

70 9.2.2. Alert Response ........................................................................

71 9.2.3. S.te Area Emergency Response ...............................................

72 9.2.4. Gmeral Emergency Response ..................................................

73 9.3. Emergency De-Escalation and Termination Criteria .................................

73 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES .................

78 10.1. Radiological Assessment

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

78 10 .1.1. D e le ted ....................................................................................

..78 10.1.2. Vari;able Trajectory Atmospheric Dispersion/Dose Projection C apability

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

..78 Emergency Plan Revision 55 Table of Contents Page ii of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued) 10.1.3. Evaluation of Offsite Air Samples .............................................

78 10.2. Protective Action Recommendation Criteria ............................................

79 10.3. Radiological Exposure Control ..................................................................

79 10.4. Protective Measures .................................................................................

80 10.4.1. Site Personnel Accountability

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

80 10.4.2. Site Egress Control Methods ....................................................

81 10.4.3. Decontamination Capability

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

81 10.4.4. Use of Onsite Protective Equipment and Supplies ....................

81 10.4.5. Fire Protection Equipment

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

81 10.5. Aid to Affected Personnel

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

82 10.5.1. Medical Treatment

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

82 10.5.2. Medical Transportation

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

82 10.6. Protective Actions for Onsite Personnel

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

82 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION

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

90 11.1. Emergency Notification

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

90 11.2. Public Notification

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

90 11.3. Public Information

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

91 12.0 MAINTAINING EMERGENCY PREPAREDNESS

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

93 12.1. Drills and Exercises

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

93 12.1.1. Radiation Emergency Drills and Exercises

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

93 12.1.2. Com munication Tests ...............................................................

93 12.1.3. Fire Drills ..................................................................................

94 12.1.4. Medical Drills ............................................................................

94 12.1.5. Radiological Monitoring Drills ....................................................

94 12.1.6. Health Physics Drills .................................................................

94 12.1.7. Security Drills ...........................................................................

95 12.1.8. Scenarios

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

95 12.1.9. Evaluation of Exercises

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

96 12.1.10. Emergency Plan Audit .............................................................

96 12.2. Training ......................................................................................................

97 12.3. Review and Updating of Plan and Procedures

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

97 12.4. Maintenance and Inventory of Emergency Equipment and Supplies ...... 98 12.5. Responsibility for the Planning Effort ........................................................

98 Emergency Plan Revision 55 Table of Contents Page iii of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

APPENDICES APPENDIX A APPENDIX B APPENDIX C APPENDIX D APPENDIX E APPENDIX F APPENDIX G APPENDIX H Emergency Classification System and Emergency Action Levels Emergency Equipment (Deleted)Environmental Laboratory Analytical and Dosimetry Services Letters of Agreement Evacuation Time Estimates Index of Emergency Plan Implementing Procedures and Support Plans Public Notification System Paqe 101 102 105 106 108 110 111 115 Emergency Plan Revision 55 Table of Contents Page iv of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

LIST OF TABLES Table 4.1 Table 4.2 Table 4.3 Table 7.1 Table 8.1 Table 8.2 Table 8.3 Table 8.4 Table 9.1 Table 10.1.1 Table 10.1.2 Table 10.2 Table 10.3 Table of Land Use 2000 Population Distribution Within the 50-Mile EPZ of Vermont Yankee Vermont Yankee "Plume Exposure" Emergency Planning Zone (10 Mile) Considerations Vermont Yankee Emergency Communications Matrix (Deleted)(Deleted)A Summary of Offsite Coordination Minimum Staffing Requirements for the ENVY ERO Vermont Yankee Emergency Response EPA Protective Action Guidelines Recommended Derived Intervention Level (DIL) or Criterion for Each Radionuclide Group Emergency Dose Limits Emergency Center Habitability and Protective Action Criteria Emergency Plan Revision 55 Table of Contents Page v of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

LIST OF FIGURES Figure 4.1 Figure 4.2 Figure 4.3 Figure 4.4 Figure 4.5 Figure 4.6 Figure 4.7 Figure 4.8 Figure 6.1 Figure 6.2 Figure 6.3 Figure 6.4 Figure 7.1 Figure 7.2 Figure 8.1 Figure 8.2 Figure 8.3 Figure 8.4 Figure 8.5 Figure 8.6 I Figure 8.7 Vermont Yankee Site Population Center and Special Interest Areas Within the 50 Mile EPZ 2000 Population Distribution Within 0-5 Miles of Vermont Yankee 2000 Population Distribution Within 0-10 Miles of Vermont Yankee 2000 Population Distribution Within 10-50 Miles of Vermont Yankee Sector Nomenclature for Vermont Yankee Plume Exposure EPZ Vermont Yankee Plume Exposure Emergency Planning Zone Vermont Yankee 50 Mile Ingestion Pathway Emergency Planning Zone Location of State and Company Emergency Operating Centers Around Vermont Yankee Technical Support Center Layout Operations Support Center Layout Emergency Operations Facility/Recovery Center Layout Plant to State Notification Channels Coordination Channels with States Defueled On-Shift Emergency Organization Vermont Yankee Defueled Emergency Management Organization Defueled Technical Support Center Emergency Organization (Deleted)Defueled Emergency Operations Facility Organization (Deleted)Defueled Joint Information Center Organization Emergency Plan Revision 55 Table of Contents Page vi of vii Entergy Vermont Yankee TABLE OF CONTENTS (Continued)

LIST OF FIGURES (Continued)

Figure 9.1 Figure 10.1 Figure 10.2 Figure 10.3 Notification Plan (Deleted)Field Sample Thyroid Dose Nomogram Medical Facilities within 50 Miles of Vermont Yankee Capable Of Handling Emergency Medical Cases Emergency Plan Revision 55 Table of Contents Page vii of vii Entergy Vermont Yankee

1.0 INTRODUCTION

In the event of an emergency at the Vermont Yankee Nuclear Power Station, officials from Vermont Yankee, local towns, the states of Vermont, New Hampshire and Massachusetts, as well as federal assistance resources, are mobilized to assess conditions and protect the health and safety of the public. This document outlines the emergency response actions that are taken by Vermont Yankee and the manner in which this response interfaces with offsite response actions.This Emergency Plan is only a part of the overall response to an emergency at Vermont Yankee. Each community within about a 10-mile radius of the plant and the states (Massachusetts, New Hampshire, and Vermont) have developed emergency response plans to be implemented if the need arises. In addition, federal agencies have specified their nuclear power plant emergency response roles and capabilities in the National Response Framework (January 2008).The objective of this document is to outline the overall response of the Company to an emergency at the site. If an abnormal situation develops, automatic initiation of plant safety systems takes place and plant operators take corrective action according to specific emergency operating procedures.

The purpose of these emergency operating procedures is to describe corrective actions necessary to restore normal plant safety margins. The emergency operating procedures also lead to the activation of the Emergency Plan in accordance with a prescribed set of emergency implementing procedures.

The Emergency Plan summarizes Vermont Yankee's emergency implementing procedures and thereby the overall response to an emergency at the site.Emergency Plan Revision 55 Page 1 of 123 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.I 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 a Notification of 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 -Specific instrument readings, system or event observation and/or radiological levels which initiate event classification, notification procedures, protective actions, and/or mobilization of the emergency response organization.

These are specific threshold readings or observations indicating system failures or abnormalities.

Emergency Assistance Personnel

-Vermont Yankee personnel who are assigned a role in the Emergency Response Organization.

Emergency Classification

-Emergencies are classified into four categories, NOTIFICATION OF UNUSUAL EVENT, ALERT, SITE AREA EMERGENCY and GENERAL EMERGENCY.

Emergency Implementing Procedure

-Specific action taken by the plant staff to activate and implement this Emergency Plan.Emergency Operations Centers -Areas designated by the state/local representatives as Emergency Plan assembly areas for their respective staffs.Emergency Operating Procedures

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

Emergency Plan Revision 55 Page 2 of 123 Entergy Vermont Yankee Emergency Operations Facility -A center established to coordinate the deployment of emergency response personnel, to evaluate offsite accident conditions and to maintain communications with offsite authorities.

Emergency Planning Zone -The areas for which planning is recommended to assure that prompt and effective actions can be taken to protect the public in the event of an accident.

The two zones are the 10-mile radius plume exposure pathway zone and the 50-mile radius ingestion pathway zone.Emergency Response Organization

-Organization comprised of Emergency Assistance Personnel who would respond and assist in a classified emergency situation.

Engineering Support Group -An engineering group established to provide emergency support for plant assessment and recovery operations.

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 system has four channels which provide separate and independent page and intercommunication capabilities.

General Emergency

-Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Hostile Action -An act toward an NPP or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other 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).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.

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.Ingestion Exposure Pathway -The pathway in which individuals receive a radiation dose due to internal deposition of radioactive materials from ingestion of contaminated water, foods, or milk.Emergency Plan Revision 55 Page 3 of 123 Entergy Vermont Yankee Joint Information Center -A center dedicated to the news media for the purpose of disseminating and coordinating information concerning accident conditions.

Activities conducted within this center will be the responsibility of the Company Spokesperson.

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.Operations Support Center -An emergency center established for available skilled emergency personnel (i.e., additional operations and support personnel).

The Operations Support Center Manager directs activities within this center.Plume Exposure Pathway -The pathway in which individuals receive a radiation dose due to: a) whole body external exposure due to gamma radiation from the plume and from deposited material; and b) inhalation exposure from the passing radioactive plume.Projected Dose -This is 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.

Protective Action Guides -Projected radiological dose values to the public which warrant protective actions following an uncontrolled release of radioactive materials.

Protective actions would be warranted provided the reduction in the individual dose is not offset by excessive risks to individual safety in implementing such actions.Recovery Actions -Those actions taken after the emergency has been controlled in order to restore safe plant conditions.

Recovery Center -An area established within the Emergency Operations facility for the purpose of planning recovery actions. The Emergency Director directs the activities of this center.Severe Accident Management

-Process that management uses to evaluate and respond to an accident that has deteriorated to a condition where the EOPs are exited and the Severe Accident Guidelines are used.Site -That property within the fenced boundary of Vermont Yankee which is owned by the Company.Emergency Plan Revision 55 Page 4 of 123 Entergy Vermont Yankee Site Area Emergency

-Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Technical Support Center -An in-plant center established in close proximity to the Control Room that has the capability to acquire plant parameters for post-accident evaluation by technical and recovery assistance personnel.

The Emergency Plant Manager directs activities within this center.Total Effective Dose Equivalent (TEDE) -The sum of the deep dose equivalent from external sources and the committed effective dose equivalent from internal exposures.

Unusual Event (Terminated)

-A condition that warrants a Notification of Unusual Event declaration, but was immediately rectified, such that the condition no longer existed by the time of declaration.

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

Emergency Plan Revision 55 Page 5 of 123 Entergy Vermont Yankee 3.0

SUMMARY

OF EMERGENCY PLAN 3.1. Objectives Safety systems at Vermont Yankee are designed to prevent and/or mitigate accidental radioactive releases.

Accordingly, the probability for a release of radioactivity resulting in a public hazard is very small. As a precautionary measure, however, this Emergency Plan specifies response actions if the safety systems are degraded or fail.The purpose of this Emergency Plan is to classify emergencies according to severity, to assign responsibilities, and to clearly outline the most effective actions to safeguard the public and plant personnel in the unlikely event of an incident at Vermont Yankee. Detailed emergency procedures at Vermont Yankee are followed by plant personnel to notify and activate the onsite and offsite emergency organizations.

These procedures are summarized in this Emergency Plan.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;3) To establish an organization for control of onsite and offsite 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 emergency response;8) To develop a communications network between the plant and offsite authorities to provide prompt notification of emergency situations;

9) To develop a training and Emergency Plan exercise program to assure constant effectiveness of the plan; and 10) To keep the public informed in a timely manner to preclude misinformation and bolster confidence in the emergency response.Emergency Plan Revision 55 Page 6 of 123 Entergy Vermont Yankee Emergencies at nuclear power plants are classified into the following four major categories (as set forth in Section 5.0): Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency.

Depending on the emergency classification, different levels of plant and offsite response are required.

Activation of emergency facilities takes place in accordance with the classification of emergency response.3.2. Actions In An Emergency If an emergency condition develops, the Shift Manager assumes the 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 Emergency Action Levels;2) Classify the accident in accordance with the emergency classification system;3) Initiate emergency operating procedure(s) applicable to the event;4) Activate the plant emergency alarm system;5) Notify state authorities in Vermont, New Hampshire and Massachusetts using the InForm Notification System;6) Notify the NRC using the Emergency Notification System;7) Use the notification plan to notify appropriate personnel as set forth in Figure 9.1 and Table 9.1;8) Depending on the emergency classification, initiate the procedures which activate the Technical Support Center, the Emergency Operations Facility/Recovery Center, the Operations Support Center, and the Joint Information Center; and 9) Direct and coordinate all emergency response efforts until overall responsibility is assumed by the Emergency Director.3.3. Emergency Response Facilities The emergency response facilities, which are utilized by the emergency response organization, are described in Section 6.0. Depending on the emergency classification, different facilities are activated and utilized.

Key site and offsite personnel are quickly dispatched to these facilities to perform accident assessments, implement corrective actions, analyze accident data, and provide public information support.Emergency Plan Revision 55 Page 7 of 123 Entergy Vermont Yankee

3.4. Mobilization

The mobilization scheme is based on the emergency notification system shown in Figure 9.1. Table 9.1 identifies the personnel notified.

The notification system utilizes the plant public address system (Gai-Tronics), dedicated telephone lines, and radio pager devices (beepers) to notify and mobilize personnel.

Key Vermont Yankee and support personnel carry pagers to expedite the mobilization process during off-hours.

Depending upon the emergency classification, different levels of mobilization are implemented.

The mobilization scheme ensures that specific technical disciplines identified by Table B-1 of NUREG-0654 can be augmented within appropriate time frames. Table 8.4 outlines the minimum staffing requirements for the Emergency Response Organization at Vermont Yankee. Table 9.1 summarizes the response to the four classes of emergencies described in Section 5.0.3.5. State Government Notification and Response Vermont Yankee's Emergency Plan interfaces with the state emergency response plans of Vermont, New Hampshire and Massachusetts.

Local town governments, in coordination with the emergency management agencies of these states, have plans, which if the need arises, contain instructions to carry out specific protective measures dependent upon various emergency conditions.

Vermont Yankee is responsible for conveying specific accident information, radiological assessment information, and protective action recommendations to the State of Vermont, State of New Hampshire, and Commonwealth of Massachusetts.

It is the responsibility of each respective state Department of Public Health to evaluate this information and make appropriate recommendation regarding public protective actions in accordance with their plans and procedures.

A cooperative arrangement exists among the Vermont, New Hampshire and Massachusetts State authorities and Vermont Yankee Nuclear Power Station concerning radiological emergency preparedness.

Vermont Yankee's emergency classification system and notification messages are reviewed and approved by these states in accordance with the terms specified in the Letter of Agreement found in Appendix E. Each state is committed to dispatching representatives to the plant's Emergency Operations Facility/Recovery Center when conditions warrant. Vermont Yankee's Joint Information Center provides the opportunity for joint utility, state and federal press briefings to be held.Emergency Plan Revision 55 Page 8 of 123 Entergy Vermont Yankee

3.6. Federal

Government Notification and Response As soon as an event is classified into one of the four categories of emergencies, notification to the NRC is made using the Emergency Notification System. 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. 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.

Principal participants are the NRC, FEMA, Department of Energy (DOE), and Environmental Protection Agency (EPA).3.7. Technical Support Technical and manpower support are provided to the Vermont Yankee plant through support plans listed in Appendix G. Support beyond this level is arranged through the Institute of Nuclear Power Operations (INPO).Emergency Plan Revision 55 Page 9 of 123 Entergy Vermont Yankee 4.0 THE AREA 4.1. The Site Vermont Yankee Nuclear Power Station is located on the west bank of the Connecticut River immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont.The Vermont Yankee Nuclear Power Station ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Entergy, with the exception of a narrow strip of land between the Connecticut River and the Vermont Yankee property for which it has perpetual rights and easements from the owner, New England Power Company.On January 12, 2015, ENO submitted a certification that a determination to permanently cease power operations was made on December 29, 2014, pursuant to 10 CFR 50.82(a)(1)(i).

ENO has submitted written certification to the NRC, in accordance with 10 CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel and placed in the Spent Fuel Pool.Upon docketing of these certifications, the 10 CFR Part 50 license for VY no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

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

4.2. Area Characteristics, Land Use and DemograDhy The site, also shown in Figure 4.1, is bounded by the Connecticut River (Vernon Pond) on the east, by farm and pasture land mixed with wooded areas on the north and south, and by the town of Vernon on the west. Warwick and Northfield State Forests (approximately 8 miles southwest of the site), Green Mountain National Forest (approximately 18 miles southwest of the site) and the Pisgah Mountain Range (northeast of the site) limit the population density and land use within a 50-mile radius of the site. Most of the land around the site is undeveloped.

Table 4.1 characterizes the land use within 25 miles of the plant.The developed land is used for agricultural, dairying, and for residential areas within small villages.

The primary agricultural crop is silage corn, which is stored for year-round feed for milk cows.Emergency Plan Revision 55 Page 10 of 123 Entergy Vermont Yankee The nearest house is 1,300 feet from the Reactor Building and is one of several west of the site. The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500 feet from the Reactor Building.

The nearest hospital, Brattleboro Memorial, is approximately five (5) miles north-northwest from the site. The nearest dairy farm is approximately 1/2-mile northwest of the site. Additional dairy farms are located within a 5-mile radius of the plant. A nursing home is located 2 miles south of the plant. These areas have been noted since they have required special planning consideration by offsite authorities in the event of a radiological emergency at Vermont Yankee.Figure 4.2 shows an overall perspective of the area within 50 miles of Vermont Yankee.The average population density within a 10-mile radius of Vermont Yankee for 2000 was estimated to be 126 people per square mile. Figures 4.3, 4.4, and 4.5 provide the 2000 population distribution within a 5-, 10-, and 50-mile radius of the Vermont Yankee Nuclear Power Station. Table 4.2 summarizes these data.Emergency Plan Revision 55 Page 11 of 123 Entergy Vermont Yankee

4.3. Emergency

Planning Zones The NRC/EPA Task Force Report on Emergency Planning, "Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light-Water Nuclear Power Plants" (NUREG-0396) established the size of planning zones for which predetermined emergency actions should be prepared.

These planning zones were selected based upon the knowledge of the potential consequences, timing and release characteristics of a spectrum of accidents (including core melt scenarios), regardless of the low probability of occurrence.

As a result, an Emergency Planning Zone concept was developed, both for short-term plume exposure and for the longer-term ingestion exposure pathways.Emergency Planning Zones (EPZs) are defined as the areas for which planning is needed to assure that prompt and effective actions can be taken to protect the public in the event of an accident.

The size of the Emergency Planning Zones represents the extent of detailed planning which should be performed to assure an adequate response.

Dependent upon the severity of the accident, protective actions are generally limited to only portions of the designated EPZs, but as the need arises, actions are undertaken for the entire zones.As a means of defining selected areas within the planning zones, Vermont Yankee divides the planning zones into sectors of 22 1/2 degrees centered on the 16 standard compass directions (see Figure 4.6). Each sector is identified by a letter ("I" and "0" are not used)and/or the standard compass direction.

Distance from the plant is defined in terms of miles radially outward from the plant.Vermont Yankee, for the purpose of radiological protection, is responsible for exercising direct control over the emergency activities within the exclusion area shown in Figure 4.1.Means of controlling access on the river is the responsibility of the State of New Hampshire.

In accordance with the recommended planning bases, Vermont Yankee has expanded its previous planning considerations by defining two Emergency Planning Zones. The plume exposure EPZ, shown in Figure 4.7, is an area designated by the jurisdictional boundaries of those communities which are within a radial distance of 10 miles from the plant site. The size of the zone is based on the following considerations:

1) projected doses estimated for most accidents would not exceed the EPA Protective Action Guides outside the zone; 2)detailed planning within this area would provide a substantial base for expansion of response efforts in the event that it is necessary;

3) planning within this area recognizes all jurisdictional restraints imposed by the zone designation.

Table 4.3 lists the local communities that are affected by this designation, the wind direction which would potentially affect these communities if a release occurs, and the sector/distance identification representing each of these communities.

As specified in the state plans, communities within the plume exposure EPZ are alerted if a major accident at Vermont Yankee occurs. Communities within this zone have their own local radiological response plans.Emergency Plan Revision 55 Page 12 of 123 Entergy Vermont Yankee The ingestion exposure pathway Emergency Planning Zone, shown in Figure 4.8, is an area within a 50-mile radius from the plant site. The size of the zone is based on the fact that the downwind range within which significant contamination could occur would generally be limited to this distance because of wind shifts and travel periods. In addition, projected doses from contamination outside this zone would not exceed the Department of Health and Human Services' ingestion pathway Protective Action guides. Four states (Vermont, New Hampshire, Massachusetts, and New York) are responsible for coordinating and implementing protective actions within this area. Precautionary measures relative to livestock feeds, milk products, garden produce, and potable water supplies are implemented in this area to the extent dictated by the release conditions.

Emergency Plan Revision 55 Page 13 of 123 Entergy Vermont Yankee TABLE 4.1 TABLE OF LAND USE (Square Miles)Distance from Site Land Use Residential Commercial and Industrial Agricultural Road Public Undeveloped TOTAL 0-10 Miles 30.2 1.3 25.9 6.0 7.2 243.4 314.0 10-25 Miles 79.2 7.7 143.8 21.6 78.3 1318.4 1649.0 1-25 Miles 109.4 9.0 169.7 27.6 85.5 1561.8 1963.0 Emergency Plan Revision 55 Page 14 of 123 Entergy Vermont Yankee TABLE 4.2 2000 POPULATION DISTRIBUTION WITHIN THE 50-MILE EPZ OF VERMONT YANKEE POPULATION TOTALS BY ZONE Ring Miles 0-1 1-2 2-3 3-4 4-5 5-10 10-20 20-30 30-40 40-50 Population 489 2496 1937 1556 3441 23954 111005 133847 337525 851123 Cumulative Miles 0-1 0-2 0-3 0-4 0-5 0-10 0-20 0-30 0-40 0-50 Population 489 2985 4922 6478 9919 33873 144878 278725 616250 1467373 POPULATION TOTALS BY SECTOR Total Population Total Population Sector 0-50 Miles Sector 0-50 Miles A B C D E F G H (N)(NNE)(NE)(ENE)(E)(ESE)(SE)(SSE)46204 36424 45230 50939 92389 188701 141941 60442 J K L M N P Q R (S)(SSW)(SW)(WSW)(W)(WNW)(NW)(NNW)458553 120057 32609 78287 44288 31855 17512 21912 Emergency Plan Revision 55 Page 15 of 123 Entergy Vermont Yankee TABLE 4.3 VERMONT YANKEE"PLUME EXPOSURE" EMERGENCY PLANNING ZONE (10 MILE) CONSIDERATIONS 1.2.3.4.5.1.2.3.4.5.1.2.3.4.5.6.7.COMMUNITIES INVOLVED Brattleboro, VT Dummerston, VT Guilford, VT Halifax, VT Vernon, VT Chesterfield, NH Hinsdale, NH Richmond, NH Swanzey, NH Winchester, NH Bernardston, MA Colrain, MA Gill, MA Leyden, MA Northfield, MA Warwick, MA Greenfield, MA APPROPRIATE SECTOR IDENTIFICATION*

P (7-10), R and Q (4-10)R and A (8-10)L (3-5), M, N and P (2-9), Q (3-6)M (9-10), N and P (8-10)F (0-2), G and H (0-4), J (0-3), K and L (0-4), M, N, and P (0-3), Q and R (0-4)A and B (5-10), C (6-10)R, A, and B (0-6), C (0-4), D and E (0-3), F (1-4), G (2-5)D, E, and F (9-10)C (8-10), D (9-10)R (6-8), A and B (5-10), C (6-10)J (3-9), K (3-10), L (3-8)L and M (9-10)H and J (7-10)K (7-10), L and M (5-10)G (4-10), H (3-10), J (3-7)F and G (6-10)J and K (8-10)AFFECTED BY WINDS BLOWING FROM ESE -S SE -SSW NNE -SSE ENE -SE ALL DIRECTIONS SSE -WSW ALL DIRECTIONS WSW-WNW SSW-W S -NW NNW- ENE NNE-E NNW- NNE N-E WNW- NNE W-NNW N -NE*Numbers in parentheses represent approximate miles from plant.Emergency Plan Revision 55 Page 16 of 123 Entergy Vermont Yankee Vermont Yankee Nuclear Power Station Vemon Elementary School Governor"-, Hunt House i N A YALEt Vemron Elydrostation Figure 4.1 Vermont Yankee Site Emergency Plan Revision 55 Page 17 of 123 Entergy Vermont Yankee Figure 4.2 Population Center and Special Interest Areas Within the 50 Mile EPZ Emergency Plan Revision 55 Page 18 of 123 Entergy Vermont Yankee N (A)NNW WNW (P)w (N) 76 (M)WSW ENE (D)E 5 (E)ESE (F)SSW (H)(J)S Figure 4.3 2000 Population Distribution Within 0 -5 Miles of Vermont Yankee Emergency Plan Revision 55 Page 19 of 123 Entergy Vermont Yankee N WNW (P)w (N)(M)WSW ENE (D)E (E)( ESE (F)(J) S Figure 4.4 2000 Population Distribution Within 0 -10 Miles of Vermont Yankee Emergency Plan Revision 55 Page 20 of 123 Entergy Vermont Yankee N (A)WNW (P)ENE (D)E (E)ESE (F)(J) S Figure 4.5 2000 Population Distribution Within 10 -50 Miles of Vermont Yankee Emergency Plan Revision 55 Page 21 of 123 Entergy Vermont Yankee 1/4°NOTE: Each sector is 221/2° and is designated by either a letter ("i" and "0" not used)or a standard compass direction identification.

Figure 4.6 Sector Nomenclature for Vermont Yankee Plume Exposure EPZ Emergency Plan Revision 55 Page 22 of 123 Entergy Vermont Yankee 0 5 10 15 Figure 4.7 Vermont Yankee Plume Exposure Emergency Planning Zone Only those portions of the communities that are within a 10-mile radius have been covered by the Public Notification System. All communities within this EPZ Boundary designation have developed an emergency plan.Emergency Plan Revision 55 Page 23 of 123 Entergy Vermont Yankee 0 10 20 30 40 50 Miles Figure 4.8 Vermont Yankee 50 Mile Ingestion Pathway Emergency Planning Zone Emergency Plan Revision 55 Page 24 of 123 Entergy Vermont Yankee

5.0 EMERGENCY

CLASSIFICATION SYSTEM The wide spectrum of component or system failures, or other occurrences that could potentially reduce plant safety margins, needs to be categorized.

For this reason, a classification system has been defined which categorizes incidents according to severity into the following four classes: Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency.

The incidents leading to each of the four emergency classifications are further identified by certain measurable and observable indicators of plant conditions called Emergency Action Levels (EALs) listed in Appendix A. Emergency Action Levels defined 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.The VY EALs and EAL bases were derived from example initiating conditions in NUMARC/NESP-007 (NEI 99-01), "Methodology for Development of Emergency Action Levels", Rev. 5, dated February 2008. The EALs and bases have been modified in accordance with Letter USNRC to VYNPS, "Vermont Yankee Nuclear Power Station -Safety Evaluation for Emergency Action Levels (TAC No. MD9157)", dated June 16, 2009.5.1. 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.Notification of Unusual Event conditions do not cause serious damage to the plant. The purpose of the Notification of Unusual Event declaration is to: 1) ensure that the first step in any response later found to be necessary has been carried out; 2) bring the operating staff to a state of readiness; and 3) ensure that appropriate offsite notifications have been made in the event that additional support is required.See Appendix A for a complete list of Emergency Action Levels corresponding to a Notification of Unusual Event.Emergency Plan Revision 55 Page 25 of 123 Entergy Vermont Yankee

5.1.1. Unusual

Event (Terminated)

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

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

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 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.Plant response and offsite notifications associated with this event classification assure that sufficient emergency response personnel, both onsite and offsite, 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 an integral portion of the emergency response required.

Plant emergency response facilities are activated at this classification.

See Appendix A for a complete list of Emergency Action Levels corresponding to an Alert.5.3. Site Area Emergency EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR LIKELY MAJOR FAILURES OF PLANT FUNCTIONS NEEDED FOR PROTECTION OF THE PUBLIC OR HOSTILE ACTION THAT RESULTS IN INTENTIONAL DAMAGE OR MALICIOUS ACTS; (1)TOWARD SITE PERSONNEL OR EQUIPMENT THAT COULD LEAD TO THE LIKELY FAILURE OF OR; (2) THAT PREVENT EFFECTIVE ACCESS TO EQUIPMENT NEEDED FOR THE PROTECTION OF THE PUBLIC. ANY RELEASES ARE NOT EXPECTED TO RESULT IN EXPOSURE LEVELS WHICH EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS BEYOND THE SITE BOUNDARY.Emergency Plan Revision 55 Page 26 of 123 Entergy Vermont Yankee The events included in this category represent a potential for offsite releases which could impact the public to the extent that protective actions may be necessary.

The purpose of the Site Area Emergency declaration is to: 1) ensure that all plant emergency response elements are mobilized;

2) ensure that monitoring teams have been dispatched, if needed;3) ensure that in-plant protective measures have been taken; 4) provide for direct interface with offsite governmental response organizations; and 5) provide updates for the public through offsite officials.

See Appendix A for a complete list of Emergency Action Levels corresponding to Site Area Emergency.

5.4. General

Emergency EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE ACTUAL OR IMMINENT SUBSTANTIAL CORE DEGRADATION OR MELTING WITH POTENTIAL FOR LOSS OF CONTAINMENT INTEGRITY OR HOSTILE ACTION THAT RESULTS IN AN ACTUAL LOSS OF PHYSICAL CONTROL OF THE FACILITY.

RELEASES CAN BE REASONABLY EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS OFFSITE FOR MORE THAN THE IMMEDIATE SITE AREA.The purpose of the General Emergency declaration is to: 1) ensure that appropriate offsite officials are adequately advised as to the extent of plant degradation;

2) provide consultation with offsite authorities in establishing appropriate protective actions for the public; 3) provide updates for the public through offsite authorities; and 4) ensure that all emergency response organizations and resources are being applied to accident mitigation.

See Appendix A for a complete list of Emergency Action Levels corresponding to a General Emergency.

5.5. Emergency

Classification System Review by State Authorities The emergency classification system specified above, as well as the EALs presented in Appendix A, is reviewed with the state authorities of Vermont, New Hampshire, and Massachusetts.

Emergency Plan Revision 55 Page 27 of 123 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 a number of emergency response facilities.

Figure 4.1 shows the relative locations of Vermont Yankee's onsite emergency response facilities.

Figure 6.1 represents the locations of the offsite support organizations' Emergency Operations Centers relative to Vermont Yankee. Descriptions of Vermont Yankee facilities and assessment capabilities are presented below.6.1. Emergency Response Facilities The emergency response organization is activated, in part or wholly, dependent upon the operating crew's recognition of Emergency Action Levels (EALs) which represent a particular emergency condition.

Facility activation may be modified or suspended if the safety of personnel may be jeopardized by a security event or other event hazardous to personnel.

Classification and subsequent declaration of the appropriate emergency condition by the Shift Manager transforms the Control Room complex into an emergency control center. Initially, the Control Room crew coordinates all phases of emergency response and corrective action required to restore the plant to a safe condition.

The Control Room staffs attention focuses on regaining plant control as emergency response personnel report and are delegated emergency functions.

The following describe each emergency response facility location.6.1.1. Technical Support Center A Technical Support Center (TSC) has been established to direct post-accident evaluation and assist in recovery operations of the plant. The TSC is located on the second floor of the Administration Building in close proximity to the Control Room and is radiologically habitable to the same degree as the Control Room for postulated accident conditions.

This center is established under the supervision of the Emergency Plant Manager and staffed by members of the TSC organization shown in Figure 8.3. A portion of the TSC, as shown in Figure 6.2, is assigned for NRC Incident Response Team members who may be dispatched to the plant. The TSC has the capability to monitor various plant parameters needed to evaluate accident conditions by accessing the plant process computer and using the diagnostic capability that its staff offers. The TSC staff can access more computer capabilities through the support plans listed in Appendix G.Emergency Plan Revision 55 Page 28 of 123 Entergy Vermont Yankee Upon activation, the TSC provides the main communication link between the plant, the Control Room, the NRC and the Emergency Operations Facility/Recovery Center. Details of this communications capability are described in Section 7.0. The plant print files are located within the TSC boundary, and contain pending and as-built system and equipment drawings, system flow diagrams, isometrics, cable/wiring diagrams, equipment outline drawings, UFSAR, Emergency Plan and plant procedures.

The TSC is activated by the Emergency Plant Manager when a plant condition exists which requires ongoing technical evaluation (i.e., Alert, Site Area or General Emergency conditions).

The TSC may be activated by the Emergency Plant Manager under a Notification of Unusual Event if conditions warrant such an action. The TSC has the capability to assess radiological conditions.

This assessment capability consists of monitoring for direct radiation and airborne particulates, and sampling and analysis for airborne radioiodine.

Appendix B lists emergency equipment found in the TSC.If staffing of the TSC is not possible due to a security event or other hazardous conditions, ERO personnel will be notified to report to an alternate location.The TSC is deactivated by the Emergency Director or the Emergency Plant Manager, depending on the emergency class, when the plant conditions have stabilized such that continuous technical assessment is no longer required.6.1.2. The Operations Support Center The Operations Support Center (OSC), which is located on the first floor of the Administration Building, provides a general assembly area for Chemistry, Radiation Protection, Maintenance, Operations, and I&C Personnel (see Figure 6.3). It is staffed with sufficient in-plant personnel required to effect protective and corrective actions in support of the emergency situation.

An Operations Support Center Manager directs the activities of this center. In-plant phone extensions and a page/intercom system provide communication capability at the OSC. Emergency equipment listed in Appendix B has been provided with additional back-up capability provided at the Radiation Protection control point. If conditions warrant evacuation of this center, the Emergency Operations Facility/Recovery Center assumes OSC functions.

The OSC remains active and staffed until terminated by the Emergency Plant Manager.If staffing of the OSC is not possible due to a security event or other hazardous conditions, ERO personnel will be notified to report to an alternate location.Emergency Plan Revision 55 Page 29 of 123 Entergy Vermont Yankee

6.1.3. Emergency

Operations Facility/Recovery Center The Emergency Operations Facility/Recovery Center (EOF/RC) is located at the Vermont Yankee Training Center on Old Ferry Road in Brattleboro, Vermont, approximately 8.75 miles from the plant site (See Figure 6.1). The EOF has a radiation protection factor of 5 and a ventilation system equipped with HEPA filters which can be isolated.

The Commission has approved this as the primary facility with no backup up EOF necessary.(NVY 84-44, February 27, 1984) The EOF, with communication capabilities for contacting the Control Room and plant Security, is available to serve as a staging area for augmented emergency response staff if the site is under threat of or experiencing hostile action. The overall responsibility for the functions performed in the EOF/RC belongs to the Emergency Director.The Emergency Director acts as the principal spokesperson for Vermont Yankee concerning all issues where an interface with offsite government authorities is required.The Radiological Assessment Coordinator is responsible for continuous evaluation of all licensee activities related to an emergency having, or potentially having, environmental radiological consequences.

The EOF/RC has sufficient space and design to accommodate the emergency response organization and responding representatives from government and industry who are responsible for limiting offsite consequences (see Figure 6.4). The EOF/RC provides information needed by federal, state, and local authorities for implementation of their offsite Emergency Plans, and a centralized meeting location for key representatives from the agencies.The EOF/RC maintains extensive communications capability with all emergency response facilities.

Section 7.0 details the extent of this capability.

Site access and control, dose assessment, sample analysis, decontamination, and recovery planning activities are directed from various locations within the EOF/RC. The EOF/RC serves as the primary evacuation, re-assembly, and off-duty augmentation personnel assembly point. Public information statements concerning the plant emergency status are transmitted from the EOF/RC to the Joint Information Center for release to the public.The following copies of emergency planning documents are available in the EOF/RC:* Site Emergency Plan and Implementing Procedures

• Area Maps* State and Local Emergency Plans* UFSAR Emergency equipment and supplies are maintained at the EOF/RC, including equipment necessary to assess radiological habitability.

This consists of monitoring for direct radiation and sampling and analysis for airborne radioparticulates and radioiodine.

For a list of EOF/RC emergency equipment, see Appendix B.Emergency Plan Revision 55 Page 30 of 123 Entergy Vermont Yankee

6.1.4. Deleted

6.1.5. Joint Information Center The Joint Information Center (JIC) provides a centralized location for conducting joint state, federal and Vermont Yankee emergency news briefings in a manner to avoid hampering ongoing emergency response proceedings.

It is expected that state and federal public information personnel will operate from the JIC.The initial designated location of the JIC is the Vermont Yankee Office Building located in Brattleboro, Vermont. If accident conditions (plume trajectory) jeopardize the habitability of this facility, the alternate JIC at Landmark College in Putney, Vermont would be utilized.At the JIC, the Company Spokesperson coordinates the generation and issuance of press releases concerning plant emergency conditions to the media. Prior to their release to the media, the Emergency Director approves releases.The JIC will be activated upon an emergency classification of an Alert or higher except as noted below.Activation of the JIC is optional prior to an Alert and is dependent on the escalation of the event and/or public interest.

Prior to the activation of the JIC, the Manager of Communications or designee would be coordinating press releases from his/her routine operations location.6.1.6. Coordination of Radiological Data Centralized coordination of the offsite radiological assessment effort with all organizations interested in and/or performing assessments is of importance to ensure that the data and its interpretation are reviewed by all parties. The number and type of organizations performing this effort vary with time and following accident declaration and offsite notification.

Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF/RC. State authorities join the EOF/RC monitoring and assessment activities.

Federal response agencies would augment plant and state radiological assessment efforts upon their arrival.Plant and state monitoring efforts are coordinated at the EOF/RC. All samples are screened for activity levels in the field. Positive results require additional analysis at the EOF/RC. Analysis is completed in two phases. Initially, the sample is evaluated for radioiodine concentration levels using gamma energy analyses instrumentation.

Having completed this analysis, total isotopic determination of activity levels is conducted using a HPGe or equivalent system. The EOF/RC sampling capability is greatly enhanced by coordinating sample transfer and analysis with the Environmental Laboratory.

Emergency Plan Revision 55 Page 31 of 123 Entergy Vermont Yankee When federal resources respond, a more suitable location than the EOF/RC may be needed. As stated by the Department of Energy (DOE), the agency charged with the lead of the federal offsite monitoring resources, this effort would be established at some location in the general vicinity of the plant site that was adequate for the equipment and manpower deployed.

Arrangements will be made for such a location with DOE and the states when it is required.

Wherever this function is located, the basic objective is to assure monitoring efforts from all organizations are coordinated.

6.2. Assessment

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

The essential monitoring systems needed for recognition of abnormal events by the plant operators are incorporated in the Emergency Action Levels specified in Appendix A. This section briefly describes monitoring systems as well as other assessment capabilities.

6.2.1. Process

Monitors Plant process monitors capability includes indications provided from various monitors located throughout the plant systems. Parameters monitored include pressure, temperature, flow, and equipment operating status. Vermont Yankee has also augmented these monitoring systems with the instrumentation to detect inadequate core cooling.The manner in which process monitors are used for accident recognition and classification is given in the detailed Emergency Action Level 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.These monitors include: 1. Main steam line radiation monitoring system, 2. Air ejector off-gas radiation monitoring system, 3. Process and liquid effluent radiation monitors, 4. Containment atmosphere radiation monitoring system, 5. Reactor Building ventilation radiation monitoring system, and 6. Plant stack radiation monitoring system.Specific details on these monitoring systems such as location, type, etc., are contained in the plant Updated Final Safety Analysis Report (UFSAR).Emergency Plan Revision 55 Page 32 of 123 Entergy Vermont Yankee In addition to installed monitoring systems, Vermont Yankee has augmented onsite radiological assessment capability to include high-range containment and stack radiation monitoring; improved in-plant iodine detection capability; and arrangements for containment atmosphere and reactor water samples.6.2.3. Meteorological Capability Vermont Yankee maintains a 300-foot primary meteorological tower from which the following parameters are measured: a Wind speed at the 35 and 297 foot levels, 0 Wind direction at the 35 and 297 foot levels, 0 Ambient temperature at the 33 foot level, and* Vertical temperature difference between the 33 and 198-foot levels and the 33 and 295 foot levels.In addition, precipitation and barometric pressure are measured on the ground.Fifteen-minute averages of the meteorological data are automatically displayed in the Control Room and the EOF/RC. These meteorological data are used to calculate offsite dispersion parameters on a real-time basis at the EOF/RC during accident conditions.

Vermont Yankee also maintains onsite a 140 foot back-up meteorological tower from which the following parameters are measured:* Wind speed at the 100 foot level,* Wind direction at the 100 foot level, and* Vertical temperature difference between the 33 -and 135-foot levels.This tower serves as a back-up to the primary tower should it fail. The meteorological data from the back-up tower are displayed on video graphic recorders located in the Control Room.In addition, Vermont Yankee has the capability to access additional meteorological information through offsite support services.

This information can be forwarded to VY dose assessment personnel upon request.Emergency Plan Revision 55 Page 33 of 123 Entergy Vermont Yankee 6.2.4. Fire Detection Devices Vermont Yankee has an extensive fire detection network which utilizes a combination of smoke detectors, thermal detectors, infrared detectors, ultraviolet detectors, and "rate of rise" detectors, as well as fire system status alarms as a means of providing plant operators with complete fire status information.

This system is described in the Vermont Yankee Fire Protection and Appendix R Program.These detection systems, in addition to providing alarm indications in the Control Room, activate automatic fire suppression systems in certain vital areas within the plant.Supplementing these systems are dry chemical and CO 2 extinguishers, standpipe systems, and a continuously available fire brigade.6.2.5. Post-Accident Sampling Post-accident sampling capability provides for emergency sample collection of containment atmosphere, plant stack halogen and particulate components, and primary coolant.Management implements radiological precautions to limit whole body exposure to 5 rem/individual for sampling and analyses conducted using these systems.6.2.6. Facilities and Equipment for Offsite Monitoring States Emergency Management and/or the system load dispatcher 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.In addition to offsite monitoring equipment at the EOF/RC, Vermont Yankee maintains an offsite environmental monitoring program. Radiological environmental monitoring stations for the site and surrounding area monitor the environment under normal and accident conditions.

Radiological environmental monitoring stations have been established in accordance with Technical Specification (Technical Requirements Manual) requirements.

In addition to the analytical capabilities of the EOF, Vermont Yankee has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities through INPO. This support may include but is not limited to the following:

Massachusetts Department of Public Health (MDPH) through the implementation of the Nuclear Incident Advisory Team (NIAT) Handbook has laboratory analysis capability at the State Contracted laboratories and those laboratories listed in the New England Interstate Radiation Assistance Plan.Emergency Plan Revision 55 Page 34 of 123 Entergy Vermont Yankee Other environmental monitoring and analysis support can be requested and arranged through INPO. The INPO Emergency Resources Manual includes the information necessary to locate and request specialized equipment and technical assistance in the area of offsite radiological monitoring.

INPO member utilities and suppliers agree to provide assistance as outlined in the INPO Emergency Resources Manual.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.

Additional offsite monitoring equipment and capability can be provided by federal agencies in accordance with the Federal Radiological Emergency Response Plan. As discussed in Section 6.1.6, this additional capability is integrated into existing efforts.Emergency Plan Revision 55 Page 35 of 123 Entergy Vermont Yankee 0 10 20 30 40 50 Miles Figure 6.1 Location of State and Company Emergency Operating Centers around Vermont Yankee Emergency Plan Revision 55 Page 36 of 123 Entergy Vermont Yankee Figure 6.2 Technical Support Center Layout Emergency Plan Revision 55 Page 37 of 123 Entergy Vermont Yankee CLEANCHEM LAB f/L Figure 6.3 Operations Support Center Layout Emergency Plan Revision 55 Page 38 of 123 Entergy Vermont Yankee WAREHOUSE HVAC ROOM ) I " NRC ROOM S I STATE ASSEMBLY MONITORING RECOVERY TEAM PLANNING COMMUNICATION NRC ROOM AREA RAD ASSESSMENT AREA CHEMISTRY AND SAMPLE ANALYSIS SECURITY LABORATORY w ADMINISTRATION ALTERNATE ALTERNATE AND FACILITY FACILITY LOG ISTICS Figure 6.4 Emergency Operations Facility/Recovery Center Layout Emergency Plan Revision 55 Page 39 of 123 Entergy Vermont Yankee

7.0 COMMUNICATIONS

The plant staff has available various means of communication systems for effective communications and coordination with offsite and onsite response organizations and/or teams.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 and the Emergency Operations Facility.

InForm consists of source and destination computers that take advantage of the internet to send Emergency Notification Forms to the States of Vermont, New Hampshire and Massachusetts during a declared emergency.

This system is staffed on a 24-hour basis on both ends -the Control Room and the State Police dispatching points. The activation of the public notification system starts with this 24-hour State Police link. InForm performs self checks every 10 seconds.Backup to the InForm Notification System is the Nuclear Alert System.7.2. Nuclear Alert System The Nuclear Alert System (NAS), originating in the Control Room, is a system of dedicated phone circuits independent of the normal land line phone system. The NAS can be used to notify the State Police of Vermont, Massachusetts, and New Hampshire of any emergency.

This system is a secure (dedicated) communications arrangement and is installed for the primary purpose of initial notification of the States, via State Police, by the plant operators.

This system is staffed on a 24-hour basis on both ends -the Control Room and the State Police dispatching points. The activation of the public notification system starts with this 24-hour State police link. NAS is tested monthly between the plant and the State Police agencies.The Nuclear Alert System also links the Control Room, the Emergency Operating Centers and Incident Field Offices of Massachusetts, New Hampshire, and Vermont, and the Emergency Operations Facility/Recovery Center (EOF/RC).

This communication system incorporates all the principal emergency response centers into a single dedicated network.The Nuclear Alert System network is shown in Figure 7.1 (Control Room Link) and in Figure 7.2 (EOF/RC Link).Backup to the NAS phone system is the commercial phone system.Emergency Plan Revision 55 Page 40 of 123 Entergy Vermont Yankee

7.3. Utility

Microwave and Radio Systems I The Utility Microwave and Radio Systems are located in the Control Room. In the event that communications fail with the NRC due to loss of the commercial telephone system, I load dispatchers are advised that Vermont Yankee will use the Utility Microwave System to provide updates of plant conditions to NRC Region I.7.4. Mobile UHF Radio System The Mobile UHF Radio System is utilized as a primary means of communications for offsite monitoring teams and security personnel; it is the alternate means of communications between the EOF/RC, the Control Room, TSC, and onsite response teams. The System consists of 100-watt UHF repeaters with high gain antennas.

These repeaters are activated by any of the six base radio stations located in the Control Room, Secondary Alarm System (SAS), TSC, Security Gate 1 and CAS, and the EOF/RC. Also, the portable units activate the repeater.

In the event the repeater fails, a "talk around" feature allows continued communications between portable units. This system is tested daily through operational use of the system.Security also has the capability to contact via radio the Windham County Sheriff Dispatcher and any Vermont State Police Patrol Vehicle(s) located in close proximity to the plant.7.5. Plant Intercom System The Intercom System (Gai-Tronics) is located in many areas throughout the plant, including the Control Room, Technical Support Center, Operations Support Center and Security Gates 1 and 2. This system consists of four channels and is utilized as a paging system during normal operations.

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 Technical Support Center; (3) coordinating activities between Control Room and the Technical Support Center; (4) calling for any missing or unaccounted for personnel that may be in the plant; and (5) communicating between the plant emergency response facilities.

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 avoid potential public telephone blockage which may occur in the event of a major emergency.

The Emergency Notification System (ENS) utilizes an FTS line which exists between the NRC Operations Office in Rockville, Maryland and the Control Room, with extensions in the Communications Room and the NRC Room (NRC Resident Inspector's Office) of the Technical Support Center. This line is tested daily by the NRC and has a 24-hour manning capability at both organizations.

Emergency Plan Revision 55 Page 41 of 123 Entergy Vermont Yankee The Emergency Notification System (ENS) also utilizes a separate FTS line between the NRC Operations Office in Rockville, Maryland and the EOF/RC.The Health Physics Network (HPN) which utilizes separate FTS lines from the TSC and EOF/RC, allows Vermont Yankee to transmit health physics and environmental information to the NRC through the Operations Center in Rockville, Maryland in a radiological event.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.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 EOF/RC, TSC, and Control Room, which will automatically activate if power is lost to the internal telephone system.7.9. Facsimile Transmission High speed, quality facsimile equipment is located at the Technical Support Center (TSC), Operations Support Center (OSC), Emergency Operations/Recovery Center, Joint Information Center (JIC), and each respective state's Emergency Operation Center (EOC).This is used to transmit pertinent data and information concerning the emergency among these facilities.

Emergency Plan Revision 55 Page 42 of 123 Entergy Vermont Yankee 7.10. Deleted Emergency Plan Revision 55 Page 43 of 123 Entergy Vermont Yankee TABLE 7.1 VERMONT YANKEE EMERGENCY COMMUNICATIONS MATRIX CALLING FRO TSC OSC CALLING TO Technical Support Center (TSC)Operations Support Center (OSC)Emergency Operations Facility (EOF)Joint Information Center (JIC)Offsite and Site Boundary Monitors Nuclear Regulatory Commission State Police (VT, NH, MA)State EOCs (VT, NH, MA)Vermont Yankee Plant Security Vermont Yankee Emergency Response Personnel CR 1,4,5,7 1,7 1,2,4 1 1,4 1,5 1,2,11 1,2,9, 11 1,4,7 1,8 1,7 1,4,10 1,10 1,4 1,5,6 1 1 1 1 1 1 1 1 M EOF 1,10 1,4 1,5,6 1,2,11 1,2,9,10, 11 1,4,7 1,8 JIC 1 1 1 1,4,7 1,7 1,8 1,8 1,8 KEY 1 2 3 4 5 6 7 8 9 10 11 Commercial Telephone System Nuclear Alert System Utility Microwave Mobile UHF Radio System Emergency Notification System Health Physics Network Gai-Tronics Personnel Pager System Southwest Fire Radio Facsimile Transmission InForm Emergency Plan Revision 55 Page 44 of 123 Entergy Vermont Yankee NOTES: 1. SEE STATE RESPONSE PLAN FOR COMMUNICATION CHANNELS BETWEEN STATE POLICE AND STATE AGENCIES AND LOCALS.2. SEE STATE RESPONSE PLAN FOR LOCALS AND OTHER STATE AGENCIES TO BE NOTIFIED.Figure 7.1 Plant to State Notification Channels Emergency Plan Revision 55 Page 45 of 123 Entergy Vermont Yankee NOTE: 1. SEE STATE RESPONSE PLANS FOR COMMUNICATION CHANNELS BETWEEN STATE EOC'S AND FWD EOC'S.2. SEE STATE RESPONSE PLAN FOR LOCALS AND OTHER STATE AGENCIES TO BE NOTIFIED........VERMONT l, VERMONT PRIMARY} ! CENTER .. .(DUMMERSTON)

-up.I* I 1 MASSACHUSETTS MASSACHUSETTS

'....- EMERGENCY OPERTIO NOTE 1 REGION III EOC 3 UNLISTED TELE. NOS.01 1-EA STATE.....................

...OlI LEGEND: O PRIMARY 0 SECONDARY ( TERTIARY-LOCAL PHONE I I I NEW HAMPSHIRE EMERGENCY OPERATIONS

• CENTER*..............

NUCLEAR ALERT SYSTEM....... INFORM Figure 7.2 Coordination Channels with States Emergency Plan Revision 55 Page 46 of 123 Entergy Vermont Yankee

8.0 ORGANIZATION

This section describes how the normal plant and engineering support organization transform into an emergency response organization to effectively deal with any incident at Vermont Yankee.8.1. Normal Plant Organization Vermont Yankee's normal operation and management organization consist of the onsite facility organization supported by the engineering and management organizations located offsite. The relationship and content of these onsite and offsite organizations are specified in the plant Technical Specifications, Technical Requirements Manual or Entergy Quality Assurance Manual.The minimum staff on duty at the plant during all shifts consists of one (1) Shift Manager, one (1) Certified Fuel Handler (CFH), three (3) Non-Certified Operators (NCO), one (1)Radiation Protection Technician and security personnel as indicated in Figure 8.1. The responsibility for determining the status of the plant in an emergency is assigned to the Shift Manager or, in his absence from the Control Room, to the CFH who has the authority and responsibility to immediately initiate any emergency actions, including emergency classification and notification.

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

Corrective action and repair, as outlined in Table 8.4, is performed by Operations staff on-shift until supplemented by additional ERO staff.8.2. Emergency Response Organization The Vermont Yankee emergency response organization is activated in part or in whole, depending upon the condition classification determined by the normal plant operations crew in the Control Room. Vermont Yankee's emergency response organization is divided into onsite and offsite elements.

The Vermont Yankee Emergency Management Organization is shown in Figure 8.2. Staffing for the onsite emergency response facilities is shown in Figure 8.3 (Technical Support Center) and Figure 8.4 (Operations Support Center).Staffing for the off-site emergency response facilities is shown in Figure 8.5 (Emergency Operations Facility/Recovery Center). All or portions of these organizations are activated depending upon the emergency classification.

Elements of the emergency response plan are activated subsequent to an emergency declaration by the Shift Manager; designated company personnel are notified and will report to designated locations.

The emergency response action of the personnel already present are performed on a priority basis depending on the emergency conditions and the immediate need which those conditions dictate as determined by the on-shift operations crew. The specific priorities facing the emergency response forces in the various locations cannot be pre-established.

They would be specific to the nature of the emergency and variable with time as it proceeds.Emergency Plan Revision 55 Page 47 of 123 Entergy Vermont Yankee Plans and procedures have been put into place to ensure the timely activation of emergency response facilities.

Although the response time will vary due to factors such as weather and traffic conditions, a goal of sixty (60) minutes for activation has been established for onsite emergency facilities including the EOF.For this reason, the coordinators and managers in the emergency response facilities are charged with the responsibility of determining the priority of response functions when initially activated and assembled, and ensuring that the needed functions be performed on the basis of the priority determination.

This process of prioritizing needs and addressing them accordingly is specified in the Emergency Plan's implementing procedures.

In emergency situations, the Shift Manager, Emergency Plant Manager, or OSC Manager can authorize actions, without following the complete work order process, if these actions prevent the following:

• Loss of important equipment, or* Personnel injury.The Emergency Plant Manager and OSC Manager are responsible for updating the Shift Manager when plant systems will be taken out and returned to service.The titles of positions in the Vermont Yankee Emergency Management Organization are shown in Figure 8.2.Emergency Plan Revision 55 Page 48 of 123 Entergy Vermont Yankee

8.2.1. Emergency

Director The Emergency Director is a manager of Vermont Yankee who 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's principal responsibilities are to: 1. Assume overall responsibility, from the Shift Manager for the response actions necessary for control of the accident and protection of emergency personnel and the public;2. Assume responsibility from the Shift Manager for offsite States' notification;(non-delegable)

3. Assume responsibility, from the Shift Manager for authorization of escalation, and de-escalation of the emergency;

4. Assume responsibility, from the Shift Manager for authorization and transmittal of offsite protective action recommendations; (non-delegable)

5. Manage all emergency elements required to restore the plant to a safe condition;

6. Coordinate accident information and assume the role of utility liaison with offsite governmental authorities;

7. Request and direct the use of outside support for recovery operations (e.g., equipment, manpower, services);

8. Resolve issues concerning operating license requirements with NRC representatives;

9. Approve public information releases; and 10. Perform or direct the emergency response organization manpower planning effort to assure the availability of sufficient staff to implement all necessary functions, should the emergency response efforts be over a prolonged period.The Emergency Director or designated alternate is notified of all emergency conditions occurring at the plant. For Alert, Site Area Emergency and General Emergency conditions, the Emergency Director reports to the EOF/RC and directs the activities of the emergency response organizations throughout the emergency condition and until the recovery activities have been terminated.

Emergency Plan Revision 55 Page 49 of 123 Entergy Vermont Yankee

8.2.2. Emergency

Plant Manager The Emergency Plant Manager has direct responsibility for the conduct of operations at the plant. During an emergency situation, the Emergency Plant Manager is responsible for the overall supervision and coordination of the onsite emergency response activities and directs the activities of the Technical Support Center until the accident is terminated.

The Emergency Plant Manager's primary responsibilities are to: 1. Direct the onsite activities required to restore the plant to a safe condition;

2. Provide technical accident assessment and support to terminate the accident;3. Analyze instrument and control problems, design and coordinate the installation of short-term modifications, and define emergency operation procedures during the modification period;4. Analyze problems in the area of system operations, determine emergency procedures related to system operations and establish shift operations support, if applicable;

5. Develop guidance for plant shift operations concerning plant protection;

6. Oversee the accumulation, retention, retrieval and transmission of vital plant parameters required to analyze the accident progression and subsequent termination;

7. Provide assistance to the Shift Manager or Emergency Director on the escalation and de-escalation of the emergency classification as conditions warrant;8. Initially direct the activities of onsite and offsite teams until EOF becomes operational.

A qualified manager assumes the role of Emergency Plant Manager under all emergency conditions.

To assist the Emergency Plant Manager, the TSC is staffed by representatives from the following departments as depicted in Figure 8.3:* Operations

• Maintenance

• Engineering

• Chemistry* Radiation Protection

• Security (stationed at the off site command post)Emergency Plan Revision 55 Page 50 of 123 Entergy Vermont Yankee

8.2.3. Shift

Manager The Shift Manager is the Duty Shift Manager. The alternate is the Control Room Supervisor of the assigned operating crew in the Control Room at the time of the emergency.

The Shift Manager is responsible for initiating emergency actions to limit the consequences of the event and bring it under control. The immediate responsibilities of the Shift Manager include performing or delegating performance of the following:

1. Recognition of emergency conditions by observation of characteristic emergency action levels (EALs);2. Classifications of accident conditions in accordance with the emergency classification system;3. Implementation of emergency operating procedures applicable to the event condition;

4. Initiation of the appropriate emergency plan implementing procedure;

5. Prompt notification of Vermont, New Hampshire and Massachusetts State Police indicating the event classification;

6. Notification of the NRC indicating the event classification;

7. Initial offsite dose assessment activities; and 8. Offsite protective action recommendation and initial transmittal to State officials.

Subsequent responsibilities undertaken by the Shift Manager include: 1. Notification of appropriate plant and company management personnel of the emergency conditions;

2. Direction and coordination of all initial emergency response efforts until the support elements of the emergency response organization are activated; and 3. Limiting the consequences of the accident and restoring the plant to a safe condition.

As part of the plant notification system, the Shift Manager has selected plant management and department head personnel notified using a radio paging/telephone system. This is the mechanism for mobilizing plant support personnel and activating the remainder of the onsite emergency response organization.

8.2.4. Deleted

Emergency Plan Revision 55 Page 51 of 123 Entergy Vermont Yankee

8.2.5. Operations

Support Center Manager A member of the plant staff is assigned to coordinate the functions of the Operations Support Center. The responsibilities of the Operations Support Center Manager include: 1. Provide system valve alignment and equipment operation support to the Shift Manager;2. Assist in coordinating recovery efforts as requested by the Emergency Plant Manager;3. Provide Radiation Protection and Chemistry support for the in-plant emergency radiation protection and sampling activities;

4. Assign available personnel to the following emergency team function as necessary:

a. Site Boundary Survey Monitoring Team b. Offsite Monitoring Teams c. Repair and Corrective Action/Rescue Team 5. Brief OSC teams on in-plant radiation protection controls.The OSC Manager directs the OSC and maintains this facility until the termination of the event. The OSC Manager establishes a base of operations in the OSC, but may find it necessary to go to the TSC from time to time.Emergency Plan Revision 55 Page 52 of 123 Entergy Vermont Yankee

8.2.6. Radiological

Assessment Coordinator During emergency conditions, the Radiological Assessment Coordinator is responsible for the development of plans and procedures to assess and control radiological exposure in support of and consistent with the emergency response and recovery organization objectives.

The primary emergency responsibilities of the Radiological Assessment Coordinator include: 1. Assess the onsite and offsite radiological conditions associated with any accidental releases.2. Evaluate offsite doses based on radiation monitoring performed by monitoring personnel;

3. Provide support to the TSC to ensure onsite protective action recommendations (i.e., decontamination procedures, protective clothing, etc.)are being considered and carried out;4. Continuously update the Emergency Director concerning dose assessment results and recommend offsite radiological protective actions to the Emergency Director;5. Recommend administrative limits for radiological exposure control of emergency workers in keeping with those specified in Table 10.2 and maintain the necessary records; and 6. Review plans and schedules of tasks with appropriate managers and coordinator of the recovery organization concentrating on radiation protection procedures.

7. Establish the coordination of radiological analysis of offsite samples;8. Receive and document all sample results;9. Coordinate the assessment activities and resolve any discrepancies with offsite response and assistance organizations.

The immediate priority of the Radiological Assessment Coordinator and staff is radiological analysis of air samples taken by offsite monitoring teams. For the long-term, additional duties include the analysis of contamination levels in area vegetables, fruits, milk, or water, and soil samples. To accomplish this long-term requirement, the Radiological Assessment Coordinator works closely with the services provided by support organizations (e.g., Environmental Lab).Emergency Plan Revision 55 Page 53 of 123 Entergy Vermont Yankee

8.2.7. Administration

and Logistics Coordinator The Administration and Logistics Coordinator is authorized to provide administrative, logistic and communication services for the emergency organization at the site.Specifically, the responsibilities of the Administration and Logistics Coordinator include: 1. Function as an aid to the Emergency Director;2. Acquire the resources required by all site emergency management disciplines;

3. Assist in arranging for near-site accommodations (i.e., housing, transportation, etc.) of incoming emergency response personnel;

4. Assist in arranging for food and potable water for personnel at all emergency response centers;5. Maintain adequate contractual communication services for the site emergency organization; and 6. Initially be responsible for procurement using established emergency procurement procedures.

NOTE: Subsequently, normal Purchasing Department operations and procedures are used as directed by the Emergency Director.The Administration and Logistics Coordinator establishes operations at the EOF/RC and assists the Emergency Director, as requested.

8.2.8. Security

Coordinator The Security Coordinator directs the security personnel in maintaining required security in support of the emergency operations.

The functional responsibilities of the Security Coordinator include: 1. Establish security around the plant site and/or any other areas identified by the Shift Manager;2. Call for required offsite police support, if necessary;

3. Manage site evacuation;

4. Provide initial accountability of personnel in the protected area; and 5. Maintain overall plant security in accordance with the Plant Security Plan.The Security Coordinator interfaces with the Emergency Plant Manager for in-plant security actions. The Security Coordinator is stationed at the off-site command post.Emergency Plan Revision 55 Page 54 of 123 Entergy Vermont Yankee 8.2.9.Company Spokesperson The Company Spokesperson is authorized to provide the public with information concerning the emergency.

The emergency responsibilities of the Company Spokesperson include: 1. Establish a Joint Information Center when necessary;

2. Coordinate information at the Joint Information Center with counterparts from local, state and federal agencies and with other companies involved with the emergency; and 3. Present terminology concerning accident conditions in an easily understood and informative manner to the press.During an emergency, the Company Spokesperson reports to the Emergency Director.The Manager of Communications or a designated alternate fills the position of the Company Spokesperson.

8.2.10. Decision Maker During implementation of Severe Accident Management (SAM), the Operations Coordinator in the TSC will assume the role of Decision Maker as defined in plant procedures.

8.2.11. Engineering Support Group The Engineering Support Group is an engineering group established to provide emergency support for plant assessment and recovery operations.

This group is activated for an Alert, Site Area and General Emergency.

The support group includes personnel from the various onsite engineering groups. In addition, the engineering support group may access offsite engineering resources through the support programs listed in Appendix G. This group resides in the Technical Support Center, and communicates with offsite technical support personnel.

This group has access to the technical expertise to provide a variety of emergency functions, such as engineering analyses and plant system assessment in support of recovery efforts.Emergency Plan Revision 55 Page 55 of 123 Entergy Vermont Yankee

8.3. 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 the public. 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 emergency response organization described in Section 8.1 and 8.2 provides the foundation for such a recovery organization.

The Emergency Director directs the recovery organization.

As indicated in Figures 8.1 through 8.5, the organization relies on more than 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. Various State and Federal support groups augment the recovery organization.

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 exposures 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;7. Provide offsite authorities with status report as to the operations capabilities of the plant;8. Provide assistance to recovery actions undertaken by state/local authorities, if requested; and 9. Provide the public with information on the status of the recovery efforts (i.e., via press, TV/radio, etc.).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 emergency proceeds in accordance with a recovery plan developed specifically for the accident conditions.

Emergency Plan Revision 55 Page 56 of 123 Entergy Vermont Yankee

8.4. Extensions

of Vermont Yankee Emergency Organization

8.4.1. Local

Service Arrangements have been made for the extension of the emergency organization capability for handling emergencies to provide for: 1. Transportation of injured personnel using an ambulance service;2. Treatment of radioactively contaminated and injured personnel at a local support hospital (Brattleboro Memorial and Baystate Franklin Medical Center)and other regional medical facilities 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 found in Appendix E, Vermont Yankee Fire Protection, Appendix R Program, and the Annual Law Enforcement Letters of Agreement (Safeguards Information) maintained by Security.8.4.2. Federal Government Support 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. Many resources are made available, as deemed necessary by the emergency condition, including a major effort under the leadership of the Department of Energy applied to the area of offsite radiological impact assessment.

This effort can involve manpower and equipment for extensive plume measurement, including aerial monitoring and tracking, and sampling and analysis of ingestion pathway media.Emergency Plan Revision 55 Page 57 of 123 Entergy Vermont Yankee

8.4.3. Additional

Support Dependent upon the emergency condition and response needs, the Vermont Yankee emergency organization 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 as referenced in Appendix G.Should response support beyond this level be required, additional support from other nuclear industry organizations can be requested through interface with the Institute of Nuclear Power Operations (INPO). Informational notifications are provided to this organization whenever emergency conditions escalate to an Alert or greater emergency condition.

The decision to request additional industry support is a responsibility of the Emergency Director.

All industry support organizations reporting to the site are assigned by emergency management, located in the EOF/RC, who specifies their authorities, responsibilities and any limits on their actions. All responding parties are required to adhere to existing plant procedures while completing their assignments.

8.5. Coordination

with State Government Authorities Because of the location of the Vermont Yankee Plant, the planning and/or action responsibilities at the state level involves coordination of three states; Vermont, New Hampshire, and Massachusetts.

Section 7.0 describes the extensive communications network between Vermont Yankee and these states as a means of promptly notifying appropriate authorities under accident conditions.

Table 8.3 provides a summary of emergency plan areas and the associated plant, state and local responsibilities.

The Shift Manager initiates the coordination effort by notifying Vermont, New Hampshire and Massachusetts State Police, providing them with an established message format that describes the accident status. Based on the emergency class, the State emergency response personnel are alerted and/or mobilized.

To ensure effective coordination of offsite emergency response actions, representatives of each state are assigned to report to the EOF/RC for first-hand emergency information and assessment.

They are provided space in the EOF/RC as shown in Figure 6.4. The Emergency Director or designee issues periodic accident reports to the responding State Representative.

Each state representative is responsible for transferring the content of these status reports to their respective State Emergency Operating Center (EOC). If additional technical expertise is required by state authorities at the state Emergency Operating Centers (EOCs), the Emergency Director can authorize dispatching of technical support staff to assist them in comprehension of any emergency communications.

Based upon the accident assessment, protective measures are recommended and implemented by each state according to actions and decisions prescribed by each state's Emergency Plan. The Vermont Health Department will notify the New York State Department of Public Health concerning all ingestion pathway considerations.

Additional state support can be called upon from any or all other New England states through the agreement specified in the New England Compact on Radiological Health Protection.

Emergency Plan Revision 55 Page 58 of 123 Entergy Vermont Yankee TABLE 8.3 (Page 1 of 3)A

SUMMARY

OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION Protective Action Decision Making PLANT RESPONSIBILITY The Shift Manager issues the initial protective action recommendation.

STATE RESPONSIBILITY State Police receive the initial notification whereupon they activate the State fan-out notification process.LOCAL RESPONSIBILITY The State Directors of Emergency Management Agencies will notify either the local emergency management directors or the selectmen of the recommended action and advise.After the Emergency Director (ED)assumes overall responsibility, the ED will issue protective action recommendations to the appropriate State authorities (non-delegable).

In the State of Vermont, the Director of the Vermont Emergency Management Agency and the Director of the Division of Occupational Health and Radiological Health and Safety would activate.In the Commonwealth of Massachusetts, the Director of the Massachusetts Emergency Management Agency and the Director of the Radiation Control Branch of the Massachusetts Department of Public health would activate.In the State of New Hampshire, the Director of the New Hampshire Office of Emergency Management and the Division of Public Health Services would activate.Emergency Plan Revision 55 Page 59 of 123 Entergy Vermont Yankee TABLE 8.3 (Continued)(Page 2 of 3)A

SUMMARY

OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION Protective Action Decision Making (continued)

PLANT RESPONSIBILITY STATE RESPONSIBILITY Each State Health representative 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.)Each State Health representative at the EOF/RC will request monitoring updates from the Lead Offsite Liaison.In the State of Vermont, the Director of the Division of Occupational

&Radiological Health & Safety will command this function at the State EOC.LOCAL RESPONSIBILITY Coordination of Radiological Data The Radiological Assessment Coordinator is responsible for compiling offsite monitoring results and for ensuring an effective deployment of monitoring personnel as well as coordinating information transfer.Local communities rely on State capability for radiological evaluation.

Emergency Plan Revision 55 Page 60 of 123 Entergy Vermont Yankee TABLE 8.3 (Continued)(Page 3 of 3)A

SUMMARY

OF OFFSITE COORDINATION EMERGENCY PLAN FUNCTION Coordination of Radiological Data (continued)

PLANT RESPONSIBILITY The Emergency Director will advise the State response personnel of results.Plant Access Control Evacuation Process Public Information Release The Security Coordinator coordinates plant site security and offsite law enforcement support as necessary.

Shift Manager will sound evacuation alarm under Site Area or General Emergencies.

OSC Manager will direct personnel to monitor all plant evacuees.The Emergency Director issues final approval prior to release.The Technical Advisor at the EOF/RC relays accident status reports to the Joint Information Center.The Company Spokesperson releases the information to the media.STATE RESPONSIBILITY In the Commonwealth of Massachusetts, the Director of the Radiation Control Branch of the Massachusetts Department of Public Health will command this function at the State EOC.In the State of New Hampshire, the Director of the Division of Public Health Services will command this function at the State EOC.State Police would respond as directed by the Directors of the Emergency Management Agencies.State Emergency management Agencies will coordinate the activation of the Public Notification System.Health and Human Services or Red Cross representative will coordinate the establishment of Reception Centers.State press personnel report to the Joint Information Center.State press personnel coordinate releases with the Company Spokesperson.

LOCAL RESPONSIBILITY Local police would assist as directed by the State Police.Media inquiries are referred to the Joint Information Center.Emergency Plan Revision 55 Page 61 of 123 Entergy Vermont Yankee Table 8.4 (Page 1 of 2)MINIMUM STAFFING REQUIREMENTS FOR THE ENVY ERO FUNCTIONAL MAJOR TASKS ENVY POSITION TITLE 1 RESPONSE AREA TIME Plant Operations

& Shift Manager (1) On Shift Assessment of Certified Fuel Handler (CFH) (1) On Shift Operational Aspects Non-Certified Operator (NCO) (3) On Shift Emergency Direction Shift Manager (1"*) On Shift& Control (Emergency Coordinator)***

Notification

/ Notify Licensee, State CFH On Shift Communication local and federal Offsite Comm/ENS Comm (1) 3 30 min.personnel

& maintain Offsite Comm/ENS Comm (2) 3 60 min.communication Radiological Emergency Operations EOF Emergency Director (1) 60 min.Accident Facility (EOF) Director Shift Mgr/CFH 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)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

/ Chem staff (1) 60 min.Radiochemistry Plant System Shift Technical Advisor Positions not needed in a Permanently Engineering Core/Thermal hydraulics Defueled Condition Electrical TSC Manager / TSC Engineering staff (1) 60 min.Mechanical TSC Manager / TSC Engineering staff (1) 60 min.Repair & Corrective Mechanical Maintenance NCO(I**) On Shift Actions Mechanical Maintenance Maintenance (1) 60 min.Rad Waste operator NCO 60 min.Electrical Maintenance

/ NCO(1 **) On Shift Instrumentation

& Control Maintenance (1) 30 min.Technician Maintenance (1) 60 min.Instrumentation

& Control Maintenance (1) 30 min.Technician I Emergency Plan Revision 55 Page 62 of 123 Entergy Vermont Yankee Table 8.4 (Continued)(Page 2 of 2)MINIMUM STAFFING REQUIREMENTS FOR THE ENVY ERO FUNCTIONAL MAJOR TASKS ENVY POSITION TITLE 1 RESPONSE AREA TIME Protective Actions Radiation protection, NCO(2**) 2 On Shift (In Plant) access control, HP RP (2) 30 min coverage for repair, RP (2) 60 min corrective actions, search& rescue, first aid &firefighting, personnel monitoring, dosimetry Fire Fighting Fire brigade* (5**) 1 On Shift Local support 30 min.Local support 60 min.Rescue Operations Fire brigade (2**) On Shift& First Aid Local support 30 min.Local support 60 min.Site Access Control Security, Security Force On Shift& Personnel communications, Accountability personnel accountability I NOTE: Response times are from NOTIFICATION of the event and are based on optimum travel conditions.

• Position staffed in accordance with Technical Requirements Manual and Administrative procedures.

• • May be provided by shift personnel assigned other functions Overall direction of facility response to be assumed by EOF director when all centers are fully staffed.Direction of minute to minute facility operations remains with senior manager in technical support center or control room.NOTES 1. AP 0894 specifies minimum shift staffing requirements.

FB requires 5 persons per TRM and the Vermont Yankee Nuclear Power Station Analysis of Proposed Post-Shutdown On-Shift Staffing.The staffing analysis was evaluated to reflect VY's permanently shutdown and defueled conditions, including the on-shift staff composition and revised accident analyses.

Titles of ENVY ERO positions are shown.2. All NCOs use digital dosimeters with features for dose rate and total dose monitoring.

NCOs are trained to self-monitor in an emergency.

3. ENVY has designated ERO members who staff positions required to meet minimum staffing to activate the TSC, OSC and EOF. The minimum staff positions required to activate the TSC and EOF are shown in E Plan Figures 8.3 and 8.5. The OSC Manager is the only position required to activate and staff the OSC. All ERO personnel are expected to respond when notified by the emergency call-in notification system.4. The on-shift Shift Manager and CFH have the capability to do initial dose assessment and PAR.The TSC and EOF radiation assessment staff relieves them of this function.Emergency Plan Revision 55 Page 63 of 123 Entergy Vermont Yankee I I L -i Fire Brigade** May be provided by shift personnel assigned other functions.

Fire Brigade positions are staffed in accordance with Technical Requirements Manual and administrative procedures.

Note, Corrective action repair is performed by Operations Staff on-shift until supplemented by the emergency response organization.

[xJ = Number of Individuals Figure 8.1 Defueled On-shift Emergency Organization.

Emergency Plan Revision 55 Page 64 of 123 Entergy Vermont Yankee Figure 8.2 VY Defueled Emergency Management Organization Emergency Plan Revision 55 Page 65 of 123 Entergy Vermont Yankee

.required for activation Figure 8.3 Defueled Technical Support Center Emergency Organization Emergency Plan Revision 55 Page 66 of 123 Entergy Vermont Yankee Dose Assessment Team

• required for activation Figure 8.5 Defueled Emergency Operations Facility Organization Emergency Plan Revision 55 Page 67 of 123 Entergy Vermont Yankee

.required for activation Figure 8.7 Defueled Joint Information Center Organization Emergency Plan Revision 55 Page 68 of 123 Entergy Vermont Yankee

9.0 EMERGENCY

RESPONSE 9.1. Emergency Condition Recognition and Classification Vermont Yankee maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and promptly declares the emergency condition as soon as possible 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 four emergency classes. The process of condition recognition, immediate response to correct the condition, event classification, and initiation of the appropriate emergency implementing procedures are all critical responsibilities of the Shift Manager and the operations crew. This has been recognized in the design of both the emergency operating and emergency implementing procedures.

The step between condition recognition and classification is handled as a procedural transition from the emergency operating procedure applicable to the event, to a specific emergency implementing procedure.

The specific transition procedure contains the listing of conditions that represents each of the four emergency categories and the detailed Emergency Action Levels (EALs) that allow the Shift Manager to determine the emergency classification.

Once the emergency is classified, the applicable emergency implementing procedure is initiated.

This is the trigger for the activation of the plant emergency response organization and the notification of offsite authorities for the activation of their emergency response.

The activation of the plant emergency response organization brings to the assistance of the operations shift personnel all the various support elements described in this plan. How specific support elements are implemented, are detailed in the emergency implementing procedures.

See Appendix G for a listing of these procedures.

9.2. Activation

of the Emergency Organization The Shift Manager activates the emergency organization if plant conditions reach predetermined Emergency Action Levels (Appendix A). Depending upon the specific action levels attained, the Shift Manager declares one of the following:

Notification of Unusual Event, Alert, Site Area Emergency, or General Emergency.

Emergency Plan Revision 55 Page 69 of 123 Entergy Vermont Yankee

9.2.1. Notification

of Unusual Event Response Appendix A defines the conditions that require the declaration of a Notification of Unusual Event. Emergencies defined within this classification demand the mobilization of specific emergency response members and the initiation of precautionary and/or corrective actions which mitigate the consequences of the event. A Notification of Unusual Event does not activate the entire emergency response organization, but may require augmentation of on-shift resources to deal with the event. Offsite emergency organizations are notified for informational purposes, and aid from offsite fire, medical, and security organizations may be required depending on the nature of the event.The response required as a result of this declaration of a Notification of Unusual Event varies according to the specified event, but a general summary of actions taken is described below: 1. The emergency condition is recognized and classified by the Shift Manager who instructs Control Room personnel to announce over the plant page system the emergency classification;

2. The on-duty operations shift and selected plant personnel respond as directed by the Shift Manager;3. Appropriate plant staff are directed to assume various emergency functions;

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

5. The NRC is notified;6. Other support is requested as necessary;

7. The Emergency Call-in Method is implemented as shown in the notification plan (Figure 9.1);8. Additional personnel report to the plant as requested by the SM;9. The Shift Manager directs the activities of emergency response personnel until overall responsibility is assumed by the Emergency Director;10. If necessary, appropriate emergency medical, fire department, or law enforcement agencies are notified and requested to respond;11. The TSC may be activated at the discretion of the Emergency Plant Manager;Emergency Plan Revision 55 Page 70 of 123 Entergy Vermont Yankee

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

9.2.1.1. Unusual Event (Terminated)

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

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

The response to this declaration of an Unusual Event (Terminated) is not as comprehensive as that for a Notification of Unusual Event. All the same notifications for a Notification of Unusual Event are made, and emergency response personnel reporting to the plant are based on specific requests of the SM.9.2.2. Alert Response An Alert requires actions to: 1) assure that sufficient emergency response personnel are mobilized to respond to the accident conditions at the site; and 2) that offsite emergency organizations are readily available to respond to the situation.

Prompt notification is made to state officials and follow-up information is provided as needed to offsite emergency organizations.

Unassigned personnel are evacuated from the site. In an Alert, the steps listed in the Notification of Unusual Event Response section (except for the termination process) and the following are performed:

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

2. The Technical Support Center, Operations Support Center, the Emergency Operations Facility/Recovery Center, and the Joint Information Center are activated by personnel as shown in Table 9.1;3. If sufficient personnel are not available onsite, off-duty personnel are called in as specified in the emergency implementing procedures;

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

5. The Emergency Director establishes operations in the EOF/RC;Emergency Plan Revision 55 Page 71 of 123 Entergy Vermont Yankee

6. The Vermont, Massachusetts, and New Hampshire state emergency response personnel, having been notified through the state fan-out process, respond in accordance with their respective Radiological Emergency Response Plans;7. The Emergency Director reports to the EOF/RC and assumes total responsibility for overall emergency response actions and recovery;8. The Joint Information Center is established and timely public information is presented through coordination between the Emergency Director and offsite authorities;

9. Offsite authorities are provided periodic meteorological assessments and, if releases are occurring, projected dose estimates. (Note: If radiological releases are occurring, monitoring teams are dispatched.);

and 10. 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 Plan Manager.9.2.3. Site Area Emergency Response In a Site Area Emergency, the steps listed in the Alert Response section and the following are performed:

1. All Vermont Yankee emergency response personnel are notified and report as described in Table 9.1;2. The Engineering Support Group works in concert with the TSC to resolve engineering support and assist in coordinating equipment resources;

3. State emergency response personnel are dispatched to the EOF/RC as state/local emergency response organizations become fully mobilized;

4. Plant conditions are continually assessed and protective action recommendations to offsite authorities are made on the basis of this assessment and/or actual or projected offsite radiological impacts;5. Termination actions are initiated in the same manner as that identified for an Alert. A closeout, de-escalation to recovery phase, or escalation of the emergency classification is made in coordination with offsite authorities.

Emergency Plan Revision 55 Page 72 of 123 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 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 55 Page 73 of 123 Entergy Vermont Yankee De-escalation from a Notification of Unusual Event to a recovery phase requires satisfying the following criteria: 1. Criticality controls are in effect;2. The fission product release has been controlled;

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

4. Notification of Unusual Event conditions have been reviewed, are under control, and are not expected to deteriorate further.De-escalation from emergency classes greater than the Notification of Unusual Event level to a recovery phase requires satisfying all the criteria stated in Items 1 through 6 above and that the States of Vermont and New Hampshire, and the Commonwealth of Massachusetts reach agreement with the Emergency Director or designee that there is no longer a need for either consideration of further public protective action or surveillance related to public protective action.When plant conditions allow de-escalation in the emergency class to a recovery phase, the Emergency Director directs the emergency response organization to perform certain response actions prior to implementing any change. These actions include: 1. Notification of all plant emergency management personnel of the pending change;2. Notification of offsite authorities of the pending change;3. Notification of corporate support services of the pending change;4. Coordination of media releases concerning the transition; and 5. Announcement of the transition over the plant page system.Emergency Plan Revision 55 Page 74 of 123 Entergy Vermont Yankee TABLE 9.1 (Page 1 of 2)VERMONT YANKEE EMERGENCY RESPONSE EMERGENCY CENTER NOTIFICATION OF UNUSUAL EVENT Activation at the discretion of the Emergency Plant Manager ALERT OR SITE AREA OR GENERAL EMERGENCY Emergency Plant Manager Technical Support Center Maintenance Coordinator (Electrical/Mechanical/l&C)

Radiological Coordinator Engineering Coordinator (Project, System, Design)Operations Coordinator OSC Manager Radiation Protection Staff Chemistry Staff Operations Support Center Not activated Spare AOs/CROs/NCOs Control Instrument Specialists Plant Mechanics Emergency Plan Revision 55 Page 75 of 123 Entergy Vermont Yankee TABLE 9.1 (Continued)(Page 2 of 2)VERMONT YANKEE EMERGENCY RESPONSE EMERGENCY CENTER Emergency Operations Facility/Recovery Center NOTIFICATION OF UNUSUAL EVENT Activation at the discretion of the Emergency Plant Manager ALERT OR SITE AREA OR GENERAL EMERGENCY Emergency Director Offsite Communicator Technical Advisor Administration and Logistics Coordinator Radiological Assessment Coordinator

• Site/Offsite Monitoring Teams Joint Information Center Not Activated Company Spokesperson

• Deployed from OSC and report to Radiological Assessment Coordinator Emergency Plan Revision 55 Page 76 of 123 Entergy Vermont Yankee (SHIFT, MANAGER Classify incident and notify: InFormi/NAS L STATE POLICE 3 STATES Notify State Authorities and Implement State Radiological Emergency Response Plan]NRC Implements National Response Framework I Gai-tronics PLANT SECURITY I ERON PLANT RESPONSE PERSONNEL Respond asassigned 3 Figure 9.1 Notification Plan Emergency Plan Revision 55 Page 77 of 123 Entergy Vermont Yankee 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES 10.1. Radiological Assessment 10.1.1. Deleted 10.1.2. Variable Trajectory Atmospheric Dispersion/Dose Projection Capability I Vermont Yankee utilizes a plume tracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiological I accident conditions.

The system assumes a variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Station site. Both continuous and intermittent releases for either ground or stack release points can be evaluated.

The effects of release height, building wake entrainment, momentum plume rise, precipitation and terrain height can be assessed in the evaluation.

Plume trajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.The model combines complex plume transport algorithms with dose assessment algorithms.

The model is programmed on a personal computer.

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

10.1.3. Evaluation of Offsite Air Samples Vermont Yankee monitoring teams, after determining the location of the plume centerline (i.e., maximum radiation level) in the field, take air samples at various intervals downwind from the plant. These samples are analyzed for gross beta/gamma activity in the field and, if elevated levels are observed, they are returned to the Emergency Operations Facility where they are analyzed to determine radionuclide concentrations.

These field results can be projected to other distances of interest.Particular attention is given to observed iodine concentrations.

Air samples are analyzed in a multi-step process. The first step involves field analysis of the sample which measures the gross radioactivity collected in the silver zeolite cartridge and filter paper using a pancake GM detector.

If the silver zeolite sample analysis shows a net count rate greater than the background count rate, the sample is immediately delivered to the EOF/RC for analysis with greater sensitivity and accuracy (for 1-131 specifically).

The projected thyroid dose is determined from the measured 1-131 concentration by multiplying the estimate of the duration of exposure by the dose conversion factor for an adult member of the public. A nomogram has been developed specifically for this thyroid dose projection on the basis of airborne radioiodine measurements.

It is shown in Figure 10.2.In addition to the measurement and evaluation of offsite direct dose rates and air samples for radioiodine, the offsite radiological impact assessment includes the identification of principal radionuclides potentially released from the accident and significant exposure pathways.Emergency Plan Revision 55 Page 78 of 123 Entergy Vermont Yankee This is accomplished through an emergency sampling program in which environmental samples of media (water, air, soil, etc., as appropriate) are collected and subjected to detailed radionuclide analysis.

The necessary analysis can be performed as described in section 6.2.6.10.2. Protective Action Recommendation Criteria In the event a General Emergency has been declared, Vermont Yankee immediately recommends protective actions to state authorities based on plant conditions.

At a minimum, the Shift Manager or Emergency Director, who is in charge of the emergency response activities, recommends that the general public be advised to seek shelter for the towns of Hinsdale, New Hampshire and Vernon, Vermont; and the towns located five miles downwind in the affected sectors.If plant conditions indicate a severe accident exists, Vermont Yankee recommends to the appropriate state officials evacuation of the towns of Hinsdale, New Hampshire and Vernon, Vermont; and all towns located five miles downwind in the affected sectors.With an emergency condition producing a radiological release or an inplant (i.e., containment) source term that could be subsequently released, one of the priorities of the responding emergency personnel is to implement the sampling and analysis of releases and/or source terms to identify if there is a radioiodine component.

This sampling capability includes containment atmosphere, gas spaces in other plant systems, and the plant stack.Radioiodine identified at any of these points is quantified and evaluated in terms of actual or potential offsite impact.Once actual source term, onsite and/or offsite field monitoring determinations have been made, the Vermont Yankee Emergency Director or designee provides projected offsite Total Effective Dose Equivalents (TEDEs) and thyroid Committed Dose Equivalents (CDEs)at various distances from the plant to the Departments of Public Health of Vermont, New Hampshire and Massachusetts.

Based upon these results, the Emergency Director recommends protective actions in accordance with the criteria set forth in the EPA Protective Action Guides, Table 10.1.1. For environmental samples collected and analyzed by Vermont Yankee, the results of these samples are coordinated with the appropriate state agencies, and the state agencies implement the appropriate ingestion pathway protective actions in accordance with the FDA/HHS document Accidental Radioactive Contamination of Human Food and Animal Feeds, issued 8/13/98. Table 10.1.2 lists the Recommended Derived Intervention Level (DIL) for each radionuclide group.10.3. Radiological Exposure Control During a plant emergency, abnormally high levels of radiation and/or radioactivity may be encountered.

These levels may range from slightly above those experienced during normal plant operation to life-endangering levels of several hundred rem in a short period of time.Under all emergency situations, immediate actions are required to regain control of the emergency or for life-saving purposes; steps should be taken to minimize personnel exposure from external and/or internal sources of radiation.

Emergency Plan Revision 55 Page 79 of 123 Entergy Vermont Yankee Table 10.2 specifies the guidelines on emergency dose limits for personnel providing emergency response duties which is consistent with the Environmental Protection Agency Emergency Worker Dose Limit Guides (EPA 400-R-92-001).

The Shift Manager initially has the responsibility to authorize emergency dose commitments until relieved by the Emergency Plant Manager. This authorization is coordinated with the assistance of the Radiological Coordinator and Radiation Protection Technicians as needed. Exposure to individuals providing emergency functions will be consistent with the limits specified in Table 10.2 with every attempt made to keep exposures ALARA.The Radiological Coordinator is responsible for developing emergency radiological protection programs for plant staff support personnel.

Emergency kits in each emergency center are provided with self-reading dosimeters (both high and low range). Each member reporting to the site will be provided a DLR badge. Dose records will be maintained at each center based upon the results of the self-reading dosimeters.

This information is cross-referenced with the DLR badge data, as soon as they can be processed at the Emergency Operations Facility/Recovery Center. The capability exists for the emergency processing of DLRs on a 24-hour per day basis, if necessary, through a General Services Agreement with Landauer Inc. Emergency workers are instructed to read self indicating dosimeters frequently, and DLRs may be processed with increased periodicity.

10.4. Protective Measures 10.4.1. Site Personnel Accountability The goal of the personnel accountability process is to account for personnel within 30 minutes of the emergency declaration of an Alert or higher. Accountability for a Notification of Unusual Event is at the discretion of the Emergency Plant Manager. Plant procedures require Security personnel at the gate to maintain a list of personnel entering or leaving the site during a site evacuation.

Emergency Response Facility Managers are responsible for accounting for their staff as they report to their facility.

Each facility maintains an organizational sign-in method which enhances this reporting process. All reports are provided to the Emergency Plant Manager in the Technical Support Center, who initiates search and rescue actions for any missing personnel.

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

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

Emergency Plan Revision 55 Page 80 of 123 Entergy Vermont Yankee 10.4.2.Site Egress Control Methods All visitors and contractors are evacuated from the plant under the Alert, Site Area or General Emergency conditions.

At the Site Area or General Emergency all visitors and contractors are directed to report to the EOF/RC for monitoring.

Emergency personnel assigned to the EOF/RC and other unassigned plant personnel, report immediately to the EOF/RC, and are monitored upon arrival at the facility.

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 area evacuation routes prior to being released.

Appendix F provides evacuation time estimates for the plume exposure EPZ, and also details the major evacuation routes that could be used in the area. Access to the plant is not allowed unless personnel are specifically authorized.

10.4.3. Decontamination Capability The in-plant decontamination facility is located in the Operations Support Center. 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 at the EOF/RC is provided by using washcloths, which are disposed of by placing them in a 55-gallon drum. If conditions warrant alternative means, the EOF/RC has emergency decontamination capability (decontamination shower with the waste draining in to a holding tank). After accident conditions have been terminated, the holding tank is sampled to ascertain whether abnormal radiological levels exist. Depending upon the activity present and the isotopic determination, plans will be developed to remove the waste for disposal.

Contaminated personnel not required for EOF activation will be directed to State Reception Centers.10.4.4. 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, all types of protective clothing, and a supply of potassium Iodide is assigned to emergency response organization members in accordance with established plant radiation protection criteria.

Radiation guideline action levels for a range of plant radiological conditions are shown in Table 10.3.10.4.5. Fire Protection Equipment The plant maintains sufficient respiratory equipment (i.e., Scott Air Pacs and spare air cylinders), to support emergency response personnel in the event of a fire. Additionally, Vermont Yankee maintains a letter of agreement with the Brattleboro Fire Department for recharging Scott Air Pac cylinders during an emergency.

Emergency Plan Revision 55 Page 81 of 123 Entergy Vermont Yankee 10.5. Aid to Affected Personnel 10.5.1.Medical Treatment In-plant medical supplies are provided in the Operations Support Center. Medical response is provided by on-shift Fire Brigade members trained in basic first-aid and Cardiopulmonary resuscitation (CPR).Arrangements exist with the hospitals indicated in Section 8.4.1. Both hospitals participate in medical emergency drills. Figure 10.3 shows hospitals within the ingestion exposure EPZ of Vermont Yankee, which have the capability to handle radiation emergencies.

10.5.2.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 Vermont Yankee on the health physics considerations associated with radioactively contaminated personnel and site access control measures.10.6. Protective Actions for Onsite Personnel A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to maintain equipment important to safe storage of spent fuel and perform the functions of the emergency plan.Emergency Plan Revision 55 Page 82 of 123 Entergy Vermont Yankee TABLE 10.1.1 EPA PROTECTIVE ACTION GUIDELINES Total Effective Dose Committed Dose Protective Action Equivalent (TEDE) Equivalent (CDE) to the Thyroid>1 rem >5 rem EVACUATION (Sheltering may be preferred protective action if the following are present:* Severe weather,* Competing disasters,* Local physical factors which impede evacuation LOCAL/STATE OFFSITE OFFICIALS WILL DETERMINE THE SIGNIFICANCE OF THESE FACTORS TO THE PAR SUBSEQUENT TO THE ISSUANCE OF THE PAR BY VY.)Emergency Plan Revision 55 Page 83 of 123 Entergy Vermont Yankee TABLE 10.1.2 RECOMMENDED DERIVED INTERVENTION LEVEL (DIL)OR CRITERION FOR EACH RADIONUCLIDE GROUP(a)(b)

All Components Of The Diet Radionuclide Group (Bg/kg) (pCi/kg)Sr-90 160 4300 1-131 170 4600 Cs-1 34 + Cs-1 37 1200 32,000 Pu-238 + Pu-239 + Am-241 2 54 Ru-103 + Ru-106' C 3 + C 6 <1 C 3 + C 6 <1 6800 450 180,000 12,000 Notes: (a)The DIL for each radionuclide group (except for Ru-1 03 + Ru-1 06) is applied independently.

Each DIL applies to the sum of the concentrations of the radionuclides in the group at the time of measurement.(b) Applicable to foods as prepared for consumption.

For dried or concentrated products such as powdered milk or concentrated juices, adjust by a factor appropriate to reconstitution, and assume the reconstitution water is not contaminated.

For spices, which are consumed in very small quantities, use a dilution factor of 10.(C) Due to the large difference in DILs for Ru-1 03 and Ru-1 06, the individual concentrations of Ru-1 03 and Ru-1 06 are divided by their respective DILs and then summed. The sum must be less than one. C3 and C6 are the concentrations, at the time of measurement, for Ru-103 and Ru-106, respectively.(from Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local Agencies, Table 2, 8/13/98)Emergency Plan Revision 55 Page 84 of 123 Entergy Vermont Yankee TABLE 10.2 EMERGENCY DOSE LIMITS(a)(refer to Notes 1 and 2)Dose Limit (refer to Note 3) Work Activity Condition 5 Rem Total Effective Dose Maintain ALARA and to extent Equivalent (TEDE) All practicable limit emergency workers to these limits 10 Rem TEDE Protecting Valuable Property Lower dose not practicable 25 Rem TEDE Lifesaving or Protection of Lower dose not practicable Large Population Lifesaving or Protection of Only on a voluntary basis to 75 Rem TEDE Large Population persons fully aware of the risks involved NOTES: 1. For emergency dose limits the following considerations should be made: a. Declared pregnant women will not be allowed to participate.

b. The use of volunteers for exposures during emergency actions is desirable.

Older workers with low lifetime accumulated effective dose should be given priority.c. The individual(s) awareness of biological consequences that such as exposure can have, including the risks associated with exposure of a developing embryo/fetus for female workers.d. All practical protective measures to limit such an exposure.e. Concurrence of individual(s) involved (i.e., voluntary risk acceptance).

f. The probability of success should be balanced against the expected exposure limit.g. The individual's familiarity with the task and speed that the individual can conduct the task.2. After the emergency has been concluded, doses received by emergency workers are required to be accounted for in accordance with 1OCFR Part 20 occupational dose limits.3. Emergency dose limits for the lens of the eye and for any organ (including skin and extremities) are three and ten times the listed values, respectively.

a EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Revised 1991 Emergency Plan Revision 55 Page 85 of 123 Entergy Vermont Yankee TABLE 10.3 EMERGENCY CENTER HABITABILITY AND PROTECTIVE ACTION CRITERIA 1. A background dose rate of 50 mRem/hr will increase the frequency of radiation monitoring in the center and require an immediate evaluation of the accumulated TEDE at the affected center.2. A reading of 1 Rem on the high-range or alarming dosimeter will initiate planning for possible evacuation to the alternate center.a) If the TSC has to be evacuated, 1) The Emergency Plant Manager and immediate staff deemed necessary to deal with the emergency should relocate to the Control Room and continue their respective roles in the Emergency Response Organization.

2) Remaining TSC staff should relocate to the EOF/RC in support of their respective disciplines or be otherwise reassigned by the Administration and Logistics Coordinator.

b) If the OSC has to be evacuated, the TSC will determine an alternate area for relocation.

3. A reading of 4 Rem on the high-range or alarming dosimeter will initiate evaluation of the need for a phased evacuation.

4. If center personnel have been or may be exposed to elevated radioiodine air concentrations in excess of 500 millirem/hr (4.0 x 10.6 microcuries/cc), evaluate the need for administration of KI for center staff and relief shift personnel.

Emergency Plan Revision 55 Page 86 of 123 Entergy Vermont Yankee Figure 10.1 Deleted Emergency Plan Revision 55 Page 87 of 123 Entergy Vermont Yankee 100000 10000 1000 i lii'U U I-)~1 I..Gd 0 100 10 I I 100HR 50 HR S20 HR 3=8 HR 4 HR 2HR 1 HR 1.OOE-04 0.01 0.01 1.OOE-09 1.OOE-08 1.00E-07 1.OOE-06 1.00E-05 1-131 Air Concentration (uCilcc)Figure 10.2 Field Sample Thyroid Dose Nomogram Emergency Plan Revision 55 Page 88 of 123 Entergy Vermont Yankee

• t -~GRAFTON --WARREN VT1:0 ""-. -,* (~~SULLIVAN

--** S*~ ~ M scutney Hosp. "N ,..S MERRIMACK" : .DSOR Springfield Hosp.Rockingham Memorial Hasp.-,. ,+m Sprinfiel

-o.BENNINGTON R-,nhm'I c I S -Grace Cottage Hosp.SARATOGA *Townhend Cheshire Medical Center WINDHAM Keene-.HILLSBORO* Brattleboro Memorial Hasp." + Brattleboro Bennington Vermont Yankee'

* Putnam Memorial , .North Adams Hosp. -,* "' L~tl NorthAdams " .RANKLIN.

.* -, l : FRANK ILIN .J-- Franklin Medical Center*Greenfield WORCESTER* IiI.-~~BERKSHIRE

-- 2 Berkshire Medical Care HAMPSHiRE Pittsfield , +CoeyDcsnHs

• * -Northampton CCT DUTCHESS LITCHFIELD 2 HARTFORD

• TOLLAND W INDHAM 0 10 20 30 40 50 Miles ( Hospital can handle contaminated patients.Figure 10.3 Medical Facilities within 50 Miles of Vermont Yankee Capable of Handling Emergency Medical Cases Emergency Plan Revision 55 Page 89 of 123 Entergy Vermont Yankee 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 11.1. Emergency Notification The Shift Manager is responsible for the notification of the State Police of Vermont, New Hampshire, and Massachusetts.

Notification is made within 15 minutes of emergency classification and is the initial link to offsite authorities for the activation of offsite emergency response plans, which includes emergency public notification if the emergency conditions warrant.The format and contents of the initial message between the plant and State Police dispatchers are specified in notification procedures and have been established with the review and agreement of those state authorities responsible for state plans.As soon as contacted via the notification procedure, the Department of Public Health of Vermont, Massachusetts and New Hampshire may call Vermont Yankee and request the following information:

1. Date, time and class of the emergency;

2. Type and quantity of release, height of release, and estimated duration/impact times;3. Prevailing weather conditions (wind velocity, direction, temperature, atmospheric stability, form of precipitation, if any);4. Actual or projected dose rates at .35 miles from the site, and projected dose rates at various distances from the plant;5. Emergency response actions underway; and 6. Recommended protective actions.These follow-up reports are provided on an as-needed basis until such time that the emergency condition has been terminated in agreement with the States of Vermont and New Hampshire, Commonwealth of Massachusetts, and Vermont Yankee plant management.

11.2. Public Notification The prompt public notification methods in the Vermont Yankee area utilize, radio, television, sirens and weather alert receivers, police and fire department mobile loudhailers and sirens, and door-to-door notification should that be required.

Details of this system are provided in Appendix H.Emergency Plan Revision 55 Page 90 of 123 Entergy Vermont Yankee 11.3. Public Information Any emergency generates a continuous and intensive demand for up-to-date information.

This is best accomplished if each organization involved is aware of what the others are saying. Consequently, Vermont Yankee has planned for the establishment of a Joint Information Center for the purpose of providing coordinated press releases during an accident.For a Notification of Unusual Event, the Manager of Communications is notified of the incident by telephone or paging system. The Manager of Communications, or designated alternate, is responsible for writing any official statements or press releases concerning the incident.

Prior to release, statements are approved by an officer of the company or designee.

Information is released directly to the press pool and the "Status Phones" are updated with this information.

In addition, the Manager of Communications notifies the appropriate departmental staff and the corporate public affairs office.For an Alert, Site Area Emergency and a General emergency, the Joint Information Center is activated and fully staffed.The Technical Advisor and required staff report to the EOF/RC for coordinating the accident information between the plant and the Joint Information Center. The Joint Information Center is staffed and provides immediate accessibility to information files and resources for the Company Spokesperson (Manager of Communications, or designated alternate) and/or the Joint Information Center staff.Regular press conferences are held at the Joint Information Center, directed by the Company Spokesperson in conjunction with appropriate state and federal organizations.

Vermont Yankee can provide 24-hour coverage at the Joint Information Center to ensure timely updates and answers to questions from visiting media representatives.

As part of Vermont Yankee's full disclosure policy, Vermont Yankee has initiated a public inquiry phone for media and public use. Normally, a prerecorded message provides, on a daily basis, routine plant information, changes in plant conditions, and other items of interest.

During an emergency, the phone is used to relay and provide up-to-date status reports regarding the situation.

Joint Information Center personnel monitor local radio and television for erroneous information concerning accident conditions.

When misinformation is recognized, corrective action is taken.Emergency Plan Revision 55 Page 91 of 123 Entergy Vermont Yankee Communication is provided between the Joint Information Center and the EOF/RC and for state and federal agency use. Public information documentation covering the following areas of concern is available:

1. Educational information on radiation;

2. Educational information on the Vermont Yankee Nuclear Power Plant;3. The emergency classification system and notification process; and 4. Planned protective actions to be implemented by state and local authorities.

Vermont Yankee assists the States of Vermont and New Hampshire and the Commonwealth of Massachusetts, to develop and ensure for dissemination on a yearly basis, brochures, calendars, and posters which provide the public with emergency planning arrangements.

The Vermont Yankee Communications Department conducts annual information programs to acquaint the news media with information concerning radiation, emergency public information procedures, the emergency classification system and a general review of plant characteristics.

Local and state media are invited and encouraged to attend.Emergency Plan Revision 55 Page 92 of 123 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 with offsite authorities.

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 agencies and the facility.A summary of exercises and drills and associated elements is outlined below.12.1.1. Radiation Emergency Drills and Exercises A full participation exercise shall be conducted every two years. 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.

State and offsite agencies may participate in drills.12.1.2. Communication Tests To ensure that emergency communications between the facility and offsite emergency response organizations are operable, communications tests are conducted as outlined below. Items 2) and 3) below can be performed as part of an Emergency plan drill or exercise.1. Communication channels with state governments within the plume exposure pathway are tested monthly;2. Communications with state Emergency Operations Center (EOCs) are conducted annually;3. Communications with assessment teams are conducted annually;4. Communications among states within the ingestion pathway are tested monthly; and 5. Communications with the NRC Headquarters Operations Officer from the Control Room, TSC and EOF are tested monthly.Emergency Plan Revision 55 Page 93 of 123 Entergy Vermont Yankee To ensure the reliability of the plant's call-in procedure, the following test/drill is performed as follows: Weekly functional test of the emergency notification system to test system performance, and Quarterly off-hours, unannounced communications drill, utilizing both the pager system and commercial telephone, to estimate emergency personnel response times.12.1.3. Fire Drills To test and evaluate the response and training of the plant's fire brigade, a number of fire drills are conducted annually.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.12.1.4. 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.12.1.5. Radiological Monitoring Drills Plant environs and radiological monitoring drills (onsite and offsite) are conducted annually.These drills include collection and analysis of airborne sample media, communications, record keeping, and interface with offsite monitoring efforts. This drill can be performed as part of an Emergency Plan drill or exercise.

Radiological monitoring drills will include interface with State offsite monitoring efforts during the biennial exercise.12.1.6. 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.Emergency Plan Revision 55 Page 94 of 123 Entergy Vermont Yankee 12.1.7. Security Drills The purpose of the Hostile Action-based drill is to maintain key skills, specifically the site-specific team skills necessary to mitigate security-based events. Hostile Action-based scenarios will be included in the drill and exercise program for exercise selection on a six-year frequency.

Full implementation should include engagement of Offsite responders and FEMA. Scenarios should address EP response actions early in the event that include aspects such as initial classification, notification, PARs if appropriate, and protective measures on site. Various scenarios should be developed to address response to different threat modes, various initiators or response capabilities.

12.1.8. 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 Vermont Yankee 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 a six-year period, the scenario content is varied to test all the major elements of the Emergency Plan Program. For full participation exercises, the scenario simulates an emergency condition and sequence that calls for the mobilization of the offsite authorities; requires the recommendation of offsite protective actions; and allows for the evaluation of offsite plans and integration with the plant response.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 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.

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, protective action recommendation, and the emergency manpower augmentation process.Emergency Plan Revision 55 Page 95 of 123 Entergy Vermont Yankee 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.

The scenario package is submitted to the NRC in accordance with current regulatory guidance.12.1.9. 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 as designated by the General Manager or a designated representative.

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.

Controllers from State Emergency Management and Health Department agencies are encouraged to join the observation and critique process.Weaknesses and/or deficiencies identified in an exercise critique are processed in accordance with the site corrective actions program.12.1.10. Emergency Plan Audit The Vermont Yankee Emergency Plan is independently audited as part of the Vermont Yankee In-plant Audit Program. The audit is conducted as part of the Entergy Quality Assurance Program in accordance with 10CFR50.54(t).

All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.Emergency Plan Revision 55 Page 96 of 123 Entergy Vermont Yankee 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 (per the Emergency Assistance Personnel List) to the emergency response organization receive annual training which includes, but is not limited to, the following:

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 unrehearsed drills or emergency 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 10CFR50.54(q).

The Emergency Plan is submitted to Vermont Yankee'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 Plan are forwarded to organization and individuals with a responsibility for implementation of the Plan. Telephone number listings associated with the emergency notification process are updated quarterly.

Emergency Plan Revision 55 Page 97 of 123 Entergy Vermont Yankee 12.4. Maintenance and Inventory of Emergency Equipment and Supplies The emergency equipment maintained in the Control Room, Operations Support Center, Technical Support Center, and the Emergency Operations Facility are listed in a checklist in Emergency Equipment Readiness Check, that is used to check readiness.

Weekly, the Operations Department conducts a test of certain emergency communications equipment.

At least quarterly in accordance with the emergency equipment inventory procedure, and subsequent to each usage, Radiation Protection Department, Chemistry Department, and other 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 Vermont Yankee. The Emergency Planning Manager is responsible for emergency planning and the interface with local and state governments.

The Emergency Planning Manager reports offsite to the Director, Emergency Programs.

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 state and local 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.

Emergency Plan Revision 55 Page 98 of 123 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.]Emergency Plan Revision 55 Page 99 of 123 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 and associated areas located in the OSC.In addition, all the resources referenced in 6.2.6 and 10.3 are at the disposal of Vermont Yankee in an emergency.

Emergency Plan Revision 55 Page 100 of 123 Entergy Vermont Yankee APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATION MAIN TECH OPS OUTER INNER CONTROL SUPPORT SUPPORT GATE GATE EQUIPMENT ROOM CENTER CENTER EOF/RC HOUSE HOUSE Respiratory Protection

• Radiation Monitoring 0 0 0 Dosimetry Sampling Communications Dose Assessment Area Map/Status Boards °Emergency References

_ °_°_ °Protective Clothing Decontamination Barrel 0 Administrative Support Status Boards Coolant Sampling Containment Air Sampling *Stack Sampling Sampling Cartridges Portable Lead Shielding Emergency Centers &Emergency Room Keys Station Sampling Cartridges Environmental Station Keys °KI I (A more detailed listing of emergency equipment is provided in"Emergency Equipment Readiness Check")OP-EQUIP-3506, Emergency Plan Revision 55 Page 101 of 123 Entergy Vermont Yankee APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATION Provided by other non-affected Entergy nuclear sites, State and EQUIPMENT Federal agencies and other utilities through INPO as needed Gamma Spectroscopy High Pressure Ion Chamber Mobile Processing DLR Unit Personnel

&Environmental DLR Badges Emergency Plan Revision 55 Page 102 of 123 Entergy Vermont Yankee APPENDIX C DELETED Emergency Plan Revision 55 Page 103 of 123 Entergy Vermont Yankee APPENDIX D ENVIRONMENTAL LABORATORY ANALYTICAL AND DOSIMETRY SERVICES Emergency Plan Revision 55 Page 104 of 123 Entergy Vermont Yankee APPENDIX D (Continued)

General In the event of a radiological emergency at Vermont Yankee, Laboratory services (as described in 6.2.6) 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.

In addition Entergy maintains a General Services Agreement with Landauer Inc. for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> emergency personnel Dosimetry processing.

Portable Emergency Analysis Equipment Portable analysis equipment including a shielded HPGe detector based gamma spectroscopy system complete 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) collected by Plant Field Sampling Teams.Emergency DLR Services The capability exists for the emergency processing of DLRs on a 24-hour per day basis, if necessary, through a General Services Agreement with Landauer Inc. Emergency workers are instructed to read self indicating dosimeters frequently, and DLRs may be processed with increased periodicity.

Portable Body Burden Service A WBC System is comprised of a portable shielded HPGe 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.Emergency Plan Revision 55 Page 105 of 123 Entergy Vermont Yankee APPENDIX E LETTERS OF AGREEMENT Letters of agreement in effect between Vermont Yankee and the offsite authorities and organizations, which under earlier revisions resided in this appendix, have been removed.These documents are now 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, including those resulting from hostile actions 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 and Baystate Franklin Medical Center have 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 for Vermont Yankee is covered in the Vermont Yankee Security Plan and are classified as safeguards information.

Emergency Plan Revision 55 Page 106 of 123 Entergy Vermont Yankee APPENDIX E (Continued)

Letters of Agreement 1. State of Massachusetts

2. State of New Hampshire 3. State of Vermont 4. Baystate Franklin Medical Center 5. National Weather Service (NOAA)6 Brattleboro Memorial Hospital 7. Rescue, Inc. Ambulance Service 8. Vernon Fire Department

9. Brattleboro Fire Department

10. Institute of Nuclear Power Operations

11. Town of Vernon 12. Department of Energy 13. DOE -REAC/TS 14. Deleted 15. State of Massachusetts Alert & Notification System 16. State of New Hampshire Alert & Notification System 17. State of Vermont Alert & Notification System 18. Landmark College 19. 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.Emergency Plan Revision 55 Page 107 of 123 Entergy Vermont Yankee APPENDIX F EVACUATION TIME ESTIMATES The Evacuation Time Estimate for Vermont Yankee Nuclear Power Station is maintained as a separate document.

The Evacuation Time Estimate is provided to offsite agencies when it is updated.Emergency Plan Revision 55 Page 108 of 123 Entergy Vermont Yankee APPENDIX G INDEX OF EMERGENCY PLAN IMPLEMENTING PROCEDURES AND SUPPORT PLANS Emergency Plan Revision 55 Page 109 of 123 Entergy Vermont Yankee APPENDIX G (Continued)

1. EMERGENCY PLAN IMPLEMENTING PROCEDURES AP 3125 EPOP-COMM-3504 EPOP-EQUIP-3506 EPOP-EREC-3507 EPOP-MED-3508 OP 3509 EPOP-OSMT-3510 EPOP-PAR-3511 EPOP-RAD-3513 EPOP-URI-10095 AP 3532 OP 3533 OP 3534 OP 3535 OP 3536 EPOP-CR-3540 EPOP-TSC-3542 EPOP-OSC-3544 EPOP-EOF-3546 EPOP-SEC-3547 EPOP-TERM-3548 AP 3549 EPOP-JIC-3550 EPOP-3551 EPOP-3552 AP 3553 AP 3554 EPAP-TRNG-3712 AP-10049 Emergency Plan Classification and Action Level Scheme Emergency Communications Emergency Equipment Readiness Check Emergency Radiation Exposure Control Onsite Medical Emergency Procedure Environmental Sample Collection during an Emergency Offsite and Site Boundary Monitoring Offsite Protective Action Recommendations Evaluation of Offsite Radiological Conditions Offsite Dose Assessment using the Unified Rascal Interface Emergency Preparedness Organization Post Accident Sampling of Reactor Coolant Post Accident Sampling of Plant Stack Gaseous Releases Post Accident Sampling and Analysis of Primary Containment In-plant Air Sample Analysis with Abnormal Conditions Control Room Actions During an Emergency Operation of the Technical Support Center Operation of the Operations Support Center Operation of the Emergency Operations Facility/Recovery Center Security Actions During an Emergency Emergency Termination and Recovery Offsite Emergency Preparedness Support Activation and Operation of the Joint Information Center Operation of the Joint Information Center When the Alternate Joint Information Center is Activated Activation and Operation of the Alternate Joint Information Center Administration and Maintenance of the Alert and Notification System Emergency Plan Teams Emergency Plan Training Equipment Important to Emergency Response Emergency Plan Revision 55 Page 110 of 123 Entergy Vermont Yankee APPENDIX G (Continued)

InForm Notification System EPAP-INFORM-1 EPOP-AFA-1008 V-EN-FAP-EP-00 V-EN-FAP-EP-01 V-EN-FAP-EP-01 V-EN-EP-202 V-EN-EP-301 Response V-EN-EP-305 V-EN-EP-306 V-EN-EP-307 V-EN-EP-308 V-EN-EP-310 V-EN-EP-401 V-EN-EP-601 V-EN-EP-801 0076 3 Alternative Facility Activation

)9 Use of KI for the Emergency Response Organization 0 Severe Weather Response 2 Severe Weather Recovery Equipment Important to Emergency Preparedness Emergency Planning Assessment of Offsite Emergency Capability Following a Natural Disaster Emergency Planning 10CFR50.54(q)

Review Program Drills and Exercises Hostile Action Based Drills & Exercises Emergency Planning Critiques Emergency Response Organization Notification System Public Use of Emergency Preparedness Owner Controlled Area Corporate Emergency Center Operations Emergency Response Organization Emergency Plan Revision 55 Page 111 of 123 Entergy Vermont Yankee APPENDIX G (Continued)

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

The State of Vermont Radiological Emergency Response Plan The State of New Hampshire Radiological Emergency Response Plan The Commonwealth of Massachusetts Radiological Emergency Response Plan for Fixed-Site Nuclear Facilities NRC Incident Response Plan (NUREG-0728)

National Response Framework (January 2008)Procedure for Admission and Management of Radioactively Contaminated Patients at Brattleboro Memorial Hospital Vermont Yankee Nuclear Power Station On-Shift Staffing Analysis Evacuation Time Estimate This list does not reference any of the emergency plan arrangements specified in Appendices D and E of this plan.Emergency Plan Revision 55 Page 112 of 123 Entergy Vermont Yankee APPENDIX H PUBLIC NOTIFICATION SYSTEM Emergency Plan Revision 55 Page 113 of 123 Entergy Vermont Yankee APPENDIX H (Continued)

Vermont Yankee has completed the installation of the equipment necessary to meet the requirements outlined in NUREG-0654 for alerting the public within the Vermont Yankee EPZ. The equipment consists of 37 sirens and NWS Tone-Alert receivers.

The attached town maps indicate the location of each siren.When an emergency condition exists which requires the Public Notification System to be activated, the emergency Management Agencies of Massachusetts, New Hampshire, and Vermont coordinate the activation of the Public Notification System (sirens, mobile PA systems, weather alert receivers, emergency broadcasting stations, etc.). After the coordination, the respective states notify local response organizations to activate the system to alert the affected population.

Coordination of the three states is very important prior to activation due to the overlap of the radio stations and sound devices outside a state into the other affected states. The responsibility for activating the prompt Public Notification System rests with the State and Local Governments.

In the event of an emergency situation, which requires rapid implementation of alerting the public, the respective state agencies (State Police and/or Emergency Management) immediately notify the Emergency Alert System (EAS) stations to provide advisory information to the public. Simultaneously, the states include the activation of the Public Notification System in their initial message to the local response organizations.

Coordination is not conducted during a fast breaking event.Emergency response organizations have a 24-hour capability of alerting and providing instructions to the public.Each state has made provisions for issuing emergency instructions to the public.Descriptions of the information to be immediately issued and updates of the information are outlined in the respective State Emergency Response Plans.Emergency Plan Revision 55 Page 114 of 123 Entergy Vermont Yankee APPENDIX H (Continued)

Siren List Map # Siren Name Siren Location 1 WI Vermont Yankee, Vernon, VT 2 W2 Fire Station, Vernon, VT 3 VV3 Recreation Center, Vernon, VT 4 BV1 Municipal Center, Brattleboro, VT 5 BV2 Town Garage, Brattleboro, VT 6 BV3 West Fire Station, Brattleboro, VT 7 BV4 Putney Road, Brattleboro, VT 8 BV5 Williams Street, Brattleboro, VT 9 BV6 State Police, Route 9, Brattleboro, VT 10 HN1 Fire Station, Hinsdale, NH 11 HN2 Town Well, Hinsdale, NH 12 WN1 Swanzey Town Line, Route 10, Winchester, NH 13 WN2 Fiddle Hill Road, Winchester, NH 14 WN3 Fire Station, Winchester, NH 15 WN4 Town Well, Route 10, Winchester, NH 16 NM1 Route 10 North, Northfield, MA 17 NM2 Fire Station, Northfield, MA 18 NM3 Lucky Clapp Road, Northfield, MA 19 DM1 Town Garage, Bernardston, MA 20 CM1 Griswoldville, Colrain, MA 21 CM2 Aunt Sophie's Peak, Colrain, MA 22 DM2 Hucklehill Road, Bernardston, MA 23 CM3 Greenfield and Leyden Roads, Colrain, MA 24 CN1 Fire Station Cupola, Chesterfield, NH 25 CN2 West Chesterfield Fire Station, Chesterfield, NH 26 CN3 Spofford Fire Station, Chesterfield, NH 27 CN4 Highway Garage, Chesterfield, NH 28 DV1 Highway Garage, Dummerston, VT 29 DV2 West Dummerston Fire Station, Dummerston, VT 30 DM3 Fire Station, Bernardston, MA 31 GM1 Northfield Mt, Hermon School, Gill, MA 32 LM1 Municipal Center, Leyden, MA 33 GV1 Front of School Corner, Guilford, VT 34 GV2 Stage Road, Guilford, VT 35 GV3 Sportsman's Club on Cremery Road, Guilford, VT 36 HN3 Filter Plant, Route 63, Hinsdale, NH 37 RN1 Whipple Hill Road, Richmond, NH Emergency Plan Revision 55 Page 115 of 123 Entergy Vermont Yankee APPENDIX H (Continued) j_-~ Al'AMERICA&N 0 / 1 SIGNAL CORPORATION MN (14.6- W) Data Zoom 12-3 Emergency Plan Revision 55 Page 116 of 123 1 Mi 11/41 11/Entergy Vermont Yankee APPENDIX H (Continued) 0 1/ 2 Data Zoom 12-3 AMERICAN M6WCORPORATION MN (14 6 W)Emergency Plan Revision 55 Page 117 of 123 Entergy Vermont Yankee APPENDIX H (Continued)

.1,~ ~. ......; .... ." ..... ..... ... ) AMERICAN 0 4 / 1/21-31/SIGNAL' CORPORATION MN (14.6- W5 Dots Zoom 12-3 Emergency Plan Revision 55 Page 118 of 123'I Entergy Vermont Yankee APPENDIX H (Continued)

SAMERICAN 0 Y4 ON MN (14 6- W) Data Zoom 12-3 Emergency Plan Revision 55 Page 119 of 123 Entergy Vermont Yankee nil APPENDIX H (Continued)

! 11C AM(l ERICAN 0 Y4 1/ '11 % Ii1%0 *) SIGNAL CORPORATION MN 114.4' W, Oats Zoom 12-3 Emergency Plan Revision 55 Page 120 of 123 Entergy Vermont Yankee 13/4 APPENDIX H (Continued) 0 % 2 % 1 11/4MN (14.5° W) Date Zoom 12-3 Emergency Plan Revision 55 Page 121 of 123 Entergy Vermont Yankee APPENDIX H (Continued)

V____ ml AMERICA 0 I 1/SIGNAL CORPORATION MN (14.6 "W Data Zoom 12-3 Emergency Plan Revision 55 Page 122 of 123 Entergy Vermont Yankee 4 2 APPENDIX H (Continued) 0 '1 1/2 3/4 1 11/2 131 Date Zoom 12-3 WAL AMERICATN'041ýA SIGNAL CORPORATION MN 114.6 Wi Emergency Plan Revision 55 Page 123 of 123 Entergy Vermont Yankee'A ATTACHMENT 9.1 10CFR50.54(q)

SCREENING PAGE 1 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/Facility/Other:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan): On 9/23/13, Entergy Vermont Yankee notified the NRC by letter BVY 13-079 of the decision to permanently cease power operations in the 4th quarter of 2014.This letter acknowledges that the Vermont Yankee 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel after the end of the operating cycle.The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018).These changes were approved by the NRC upon issuance of License Amendment 261. (Change summary attached)The Emergency Plan and the following documents have been revised to incorporate the approved License Amendment for the SAFSTOR Emergency Plan and Emergency Response Organization (ERO). See attached change summaries for each document.* Cancel V-EN-TQ-110, Emergency Response Organization, Rev 11 and V-EN-TQ-110-01, Fleet Eplan Training Course Summary, Rev 2 to the SAFSTOR Emergency Planning Training Program Description

• EPOP-TSC-3542, Operation of the Technical Support Center (TSC), Rev 02* EPOP-OSC-3544, Operation of the Operations Support Center (OSC), Rev 01* EPOP-EOF-3546, Emergency Operations Facility/Recovery Center (EOF/RC), Rev 03* EPOP-JIC-3550, Activation and Operation of the Joint Information Center, Rev 01* EPOP-3551, Operation of the Joint Information Center when the Alternate Joint Information Center is Activated, Rev 01* EPOP-3552, Activation and Operation of the Alternate Joint Information Center, Rev 01* V-EN-EP-801, Emergency Response Organization

• AP 0894, Staffing Limits Part II. Activity Previously Reviewed?

UYES [L NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3)

Continue to Alert and Notification System Design Report? Evaluation is next part NOT required.Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and proposed change is documented below: complete Part VI. cnidceebo Justification:

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

References:

BVY 13-079; BVY 14-018 EN-EP-305 REV 3 ATrACHMENT 9.1 PAGE 2 OF 7 10CFR50.54(q)

SCREENING Procedure/Document Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/Facility/Other:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)Part III. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-1 00)NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

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

Screening.

El One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3)

Screening for that portion of the activity.

Identify the applicable controlling change processes below.0I One or more controlling change processes are selected and fully bounds all aspects of the activity.

50.54(q)(3)

Evaluation is NOT required.

Identify controlling change processes below and complete Part VI.CONTROLLING CHANGE PROCESSES 10CFR50.54(g)

Part IV. Editorial Change UYES Z NO 50.54(q)(3)

Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.Justification:

Enter justification and complete Part VI.Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets)

Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section I1?1. Responsibility for emergency response is assigned.

[1] El 2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 El staffing) in accordance with the emergency plan. [1]3. The process ensures that on shift emergency response responsibilities are staffed and assigned.

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

[2] El 5. Arrangements for requesting and using off site assistance have been made. [3]6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] El 7. A standard scheme of emergency classification and action levels is in use. [4] El 8. Procedures for notification of State and local governmental agencies are capable of alerting them of [the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications.

[5]9. Administrative and physical means have been established for alerting and providing prompt LI instructions to the public within the plume exposure pathway. [5]10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and El Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]11. Systems are established for prompt communication among principal emergency response organizations.

[6]EN-EP-305 REV 3 ATTACHMENT 9.1 PAGE 3 OF 7 10CFR50.54(q)

SCREENING Procedure/Document Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/Facility/Other:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)12. Systems are established for prompt communication to emergency response personnel.

[6] El 13. Emergency preparedness information is made available to the public on a periodic basis within the ET plume exposure pathway emergency planning zone (EPZ). [7]14. Coordinated dissemination of public information during emergencies is established.

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

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

[8] El 17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] El 18. A range of public PARs is available for implementation during emergencies.

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

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

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

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

[12] El 23. Plans for recovery and reentry are developed.

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

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

[14]26. Identified weaknesses are corrected.

[14] El 27. Training is provided to emergency responders.

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

[16] El 29. Planners responsible for emergency plan development and maintenance are properly trained. [16] El EN-EP-305 REV 3 ATTACHMENT 9.1 PAGE 4 OF 7 IOCFR50.54(q)

SCREENING ProcedurelDocument Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/FacilitylOther:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)APPLICABILITY CONCLUSION O If no Part V criteria are checked, a 50.54(q)(3)

Evaluation is NOT required; document the basis for conclusion below and complete Part VI.Ui If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3)

Evaluation.

BASIS FOR CONCLUSION Part VI. Signatures:

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

Reviewer Name (Print) Reviewer Signature Date: Reviewer Name (Print) Reviewer Signature Date: Tom Sowdon /2/4/15 Nuclear EP Project Manager Approver Name (Print) Approver Signature Da MP McKenney ..EP manager or designee 9- " V EN-EP-305 REV 3 ATTACHMENT 9.1 IOCFR50.54(q)

SCREENING PAGE 5 OF 7 ProcedurelDocument Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/FacilitylOther:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)Emer-gency Planning Training Pro-gram Description

• Developed training for new SAFSTOR organization to match the staffing changes in BVY 14-018 EPOP-TSC-3542, Operation of the Technical Support Center (TSC). Rev 02 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

• TSC Manager* Reactor Engineer* Manpower and Planning Liaison* TSC Communicator

• TSC Engineer* IT Specialist EPOP-OSC-3544.

Operation of the Operations Support Center (OSC). Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

• Operations Support* I&C/Electrical Coordinator

• Mechanical Coordinator

• Rad/Chem Coordinator

• Work Control Coordinator

• OSC Log Keeper EPOP-EOF-3546.

Emer-gency Operations Facility/Recovery Center (EOF/RC).

Rev 03 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

• EOF Manager* EOF Communicator

• Public Information Liaison* Emergency Planning Coordinator

• IT Specialist

• EOF Log Keeper EPOP-JIC-3550.

Activation and Operation of the Joint Information Center, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

• Information Coordinator

• Press Release Writer* Logistics Coordinator

• Technical Assistant* JIC Log Keeper* Inquiry Response Coordinator

• Media Monitor/Status Phone Recorder* Credentialing EN-EP-305 REV 3 ATTACHMENT 9.1 10CFR5O.54(q)

SCREENING PAGE 6 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/Facility/Other:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)EPOP-3551.

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

• Information Coordinator

• Press Release Writer* Logistics Coordinator

• Technical Assistant* Inquiry Response Coordinator

• Media Monitor/Status Phone Recorder EPOP-3552.

Activation and Operation of the Alternate Joint Information Center, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions:

• Logistics Coordinator

• Credentialing

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

• TSC Manager* Reactor Engineer* Manpower and Planning Liaison* TSC Communicator

• TSC Engineer* IT Specialist

• Operations Support I I&C/Electrical Coordinator

• Mechanical Coordinator

• Rad/Chem Coordinator

• Work Control Coordinator

• OSC Log Keeper* EOF Manager* EOF Communicator

• Public Information Liaison* Emergency Planning Coordinator

• IT Specialist

• EOF Log Keeper* Information Coordinator

• Press Release Writer* Logistics Coordinator

• Technical Assistant* JIC Log Keeper* Inquiry Response Coordinator

• Media Monitor/Status Phone Recorder* Credentialing Removed all information pertaining to other Entergy sites EN-EP-305 REV 3 ATTACHMENT 9.1 PAGE 7 OF 7 10CFR50.54(q)

SCREENING Procedure/Document Number: Emergency Plan & Emergency Plan Revision:

Various Implementing Procedures Equipment/FacilitylOther:

Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)AP 0894, Staffinq Limits Revised on shift staffing to match the License Amendment 261 from the NRC EN-EP-305 REV 3 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 1 OF 52 I. OVERVIEW PAD Rev. #: 0 Facility:

Vermont Yankee Proposed Activity / Document:

Emergency Plan Change/Rev.

1. 55 Description of Proposed Activity: The proposed changes to the Emergency Plan are shown in a table following section VIII.This PAD covers the changes to the Emergency Plan approved by the NRC in License Amendment 261 (Ref: NVY 15-010) to reduce staffing for the Emergency Response Organization.

The changes to staffing levels approved by License Amendment 261 include:* Table 8.4, "Minimum Staffing Requirements for the ENVY ERO"* Table 8.3, "A Summary of Off-site Coordination"* Figure 8.2, 'VY Emergency Management Organization"* Figure 8.3, "Technical Support Center Emergency Organization"* Figure 8.4, "Operations Support Center Emergency Organization"" Figure 8.5, "Emergency Operations Facility Organization"" Figure 8.7, "Joint Information Center Organization"" Table 9.1, 'Vermont Yankee Emergency Response" All other changes to reflect a permanently defueled facility were performed under the 10CFR50.54(q) process.II. DOCUMENT REVIEW Provide the requested information for each item below.1. For documents available electronically:

a. List search engine or documents searched, and keywords used: Documents Searched:

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

b. List relevant sections of controlled electronic documents reviewed: UFSAR -Section 7.15, Process Computer System; Section 13.6, Emergency Plan Emergency Plan -Entire document EN-LI-100 REV. 16 ATTACHMENT 9.1 PAGE 2 OF 52 2. Documents reviewed manually (hardcopy):

PROCESS APPLICABILITY DETERMINATION FORM Emergency Plan: Figure 4.1, 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, 4.8, 6.1, 6.2, 6.3, 6.4, 7.1, 7.2, 8.1, 8.2, 8.3, 8.4, 8.5, 8.7, 9.1, 10.1, 10.2 & 10.3 3. For those documents that are not reviewed either electronically or manually, use the specific questions provided in Sections III and IV of Attachment 9.2 of EN-LI-100 as needed. Document below the extent to which the Attachment

9.2 questions

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

EN-LI-100 REV. 16 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 3 OF 52 III. PROCESS REVIEW Does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following processes?

Associated regulations and procedures are identified with each process below.PROCESS (Regulations I Procedures)

YES NOý REVIEW RESULTS Chemistry I Effluents El 0 Radwaste I Process Control Program (PCP) El 0 (EN-RW-105 or contact the Radiation Protection Dept.)Radiation Protection I ALARA El 0 (10 CFR 20 / EN-RP-1 10 or contact the Radiation Protection Dept.)Inservice Inspection Program (10 CFR 50.55a / EN-DC-120, -351) E] 0D Inservice Testing Program (10 CFR 50.55a I EN-DC-332)

El 0 Maintenance Rule Program (10 CFR 50.65/ EN-DC-203, -204, -205, -206, 0l 0-207) -Containment Leakage Rate Testing (Appendix J) Program (10 CFR 50 El 0 Appendix J / EN-DC-334)

PROCESS (Regulatlons/Procedures)

YES NO N/A REVIEW RESULTS Flex Program (NRC Order EA.12-491FLEX Program) (10CFR50.59 I El El 0 Contact Design Engineering)

NOTE: The date for individual Site Implementation of the FLEX Program is not the same for all sites. All sites are required to implement a FLEX program per NRC Order EA-1 2-49. N/A may be used for this process by sites that have not completed implementation of a FLEX program. Contact Design Engineering if further assistance is needed.IF any box is checked "Yes," THEN contact the appropriate department to ensure that the proposed change is acceptable and document the results in the REVIEW RESULTS column.EN-LI-I00 REV. 16 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 4 OF 52 IV. LICENSING BASIS DOCUMENT REVIEW Does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Document(s)?

Associated regulations and procedures are identified with each Licensing Basis Document below.LICENSING BASIS DOCUMENTS YES NO REVIEW RESULTS OR SECTIONS (Regulations I Procedures)

AFFECTED OR LBDCR #Quality Assurance Program Manual (QAPM) [ 0 (10 CFR 50.54(a) / EN-QV-104)

Fire Protection Program (FPP) [includes the Fire Safety AnalysislFire Hazards Analysis (FSAIFHA)]

El 0 OL Condition, 10 CFR 50.48 / EN-DC-128)

Emergency Plan (10 CFR 50.54(q) / EN-EP-305) 0 El Screened lAW EN-EP-305 Environmental Protection Plan (Appendix B of the OL, Environmental Evaluation

/ EN-EV- 115, EN-EV-1 17, El 0 No EPP at VY EN-LI-1i03)

Security Plan and Cyber Security Plan C1 0[10 CFR 50.54(p) / EN-NS-210 or contact the site Security / IT Dept.]Operating License (OL) I Technical Specifications (TS) D3* 09 (10 CFR 50.90/ EN-LI-103)

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

/ EN-Li-1 01) E] 0 Technical Requirements Manual (TRM) (including TRM Bases) El 0 (10 CFR 50.59 / EN-LI-100

/ EN-LI-101)

Core Operating Limits Report (COLR), and Pressure and Temperature Limits Report (PTLR) (TS Administrative Controls, EN-LI-1 13, EN-LI-1 00, El 0 EN-LI-101)

Offslte Dose Calculation Manual (ODCM)(TS Administrative Controls or 10 CFR 50.59 / EN-LI-113 or EN-LI-100/

El 0 EN-LI-101)

Updated Final Safety Analysis Report (UFSAR) UFSAR markups to reflect termination (10 CFR 50.71(e) / EN-LI-113, EN-LI-1 00, EN-LI-101) 0 El of the Emergency Response Data System have been submitted to Licensing Storage Cask Certificate of Compliance (10 CFR 72.244/ EN-LI-113)

El* 0 Cask FSAR (CFSAR) (including the CTS Bases) -0 (10 CFR 72.70 or 72.248 / EN-LI-1 13, EN-LI-100,EN-LI-1 12)10 CFR 72.212 Evaluation Report (212 Report) El1 0 (10 CFR 72.48 / EN-LI-100, EN-LI-112)

NRC Orders (10 CFR 50.90 / EN-LI-103 or as directed by the Order) E* 09 NRC Commitments and Obligations (EN-LI-110) 10 Site Specific CFR Exemption E] 01 (10 CFR 50.12, 10 CFR 55.11, 10 CFR 55.13, 10 CFR 72.7)*Contact the site Regulatory Assurance Department if needed.IF any box is checked "Yes," THEN ensure that any required regulatory reviews are performed in accordance with the referenced procedures.

Prepare an LBDCR per procedure EN-LI-113, as required, if a LBD is to be changed, and document any affected sections or the LBDCR #. Briefly discuss how the LBD is affected in Section VII.A.EN-LI-100 REV. 16 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM ATTACHMENT

9.1 PROCESs

APPLICABILITY DETERMINATION FORM PAGE 5 OF 52 V. 10 CFR 50.59 / 10 CFR 72.48 APPLICABILITY Can the proposed activity be dispositioned by one of the following criteria?

Check the appropriate box (if any).El An approved, valid 50.59172.48 Evaluation covering associated aspects of the proposed activity already exists. Reference 50.59/72.48 Evaluation

1. (if applicable) or attach documentation.

Verify the previous 50.59/72.48 Evaluation remains valid.[ The NRC has approved the proposed activity or portions thereof or a license amendment being reviewed by the NRC addresses the proposed activity.

Reference the approval document:

Licensing Amendment 261[ The proposed activity is controlled by one or more specific regulations.

Examples of programs controlled by specific regulations are:* Maintenance Rule (50.65) (EN-DC-203)

• Quality Assurance Program (10 CFR 50 Appendix B) (EN-QV-104)" Security Plan [50.54(p)] (EN-NS-210)" Emergency Plan [50.54(q)] (EN-EP-305)

• Fire Protection Program (operating license condition)" Inservice Inspection Program (50.55a) (EN-DC-351)

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

Reference the controlling specific regulation(s):

10CFR50.54(q)

IF the entire proposed activity can be dispositioned by the criteria in Section V, THEN 50.59 and 72.48 Screenings are not required.

Proceed to Section VII and provide basis for conclusion in Section VIIA.Otherwise, continue to Section VI to perform a 50.59 and/or 72.48 Screening, or perform a 50.59 and/or 72.48 Evaluation in accordance with EN-LI-101 and/or EN-LI-112.

Changes to the IPEC Unit I Decommissioning Plan are to be evaluated in accordance with the 50.59 process, as allowed by the NRC in a letter to IPEC dated January 31, 1996. [Merlin Document ID: RA-96-014]

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APPLICABILITY DETERMINATION FORM PAGE 6 OF 52 VI. 50.59 / 72.48 SCREENING REVIEW (All proposed activities should be evaluated to determine if 50.59, 72.48 or both apply, check the boxes as appropriate)

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

The proposed activity meets all of the following criteria: " Does not adversely affect the design function of an SSC as described in the UFSAR; AND* Does not adversely affect a method of performing or controlling a design function of an SSC as described in the UFSAR; AND* Does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC will be accomplished as described in the UFSAR; AND* Does not involve a test or experiment not described in the UFSAR.IF 10 CFR 50.59 applies, but the proposed activity does not meet the applicable criteria, THEN perform a II 50.59 Evaluation in accordance with EN-LI-101, attach a copy of the Evaluation to this form, and proceed to Section VII.VI.B 72.48 SCREENING El 10 CFR 72.48 Screening criteria are met. [10 CFR 72.48(c)(1)] (Applicable to sites with an ISFSI)The proposed activity meets all of the following criteria: " Does not adversely affect the design function of an SSC as described in the CFSAR; AND* Does not adversely affect a method of performing or controlling a design function of an SSC as described in the CFSAR; AND" Does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC will be accomplished as described in the CFSAR; AND" Does not involve a test or experiment not described in the CFSAR.IF 10 CFR 72.48 applies, but the proposed activity does not meet the applicable criteria, THEN E] perform a 72.48 Evaluation in accordance with EN-LI-112, attach a copy of the Evaluation to this form, and proceed to Section VII.EN-LI-100 REV. 16 ATTACHMENT 9.1 PAGE 7 OF 52 VI.B BASIS PROCESS APPLICABILITY DETERMINATION FORM Provide a clear, concise basis for determining the proposed activity may be screened out such that a third-party reviewer can reach the same conclusions.

Identify the relevant design function, as appropriate.

Refer to NEI 96-07 Section 4.2 for guidance.

Refer to NEI 12-06 Section 11.4, regarding FLEX. Provide supporting documentation or references as appropriate.

I VII. REGULATORY REVIEW

SUMMARY

VII.A GENERAL REVIEW COMMENTS (Provide pertinent review details and basis for conclusions if not addressed elsewhere in form.)The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). These changes were approved by the NRC upon issuance of License Amendment 261. No additional evaluation is required for these changes.Other changes to the Emergency Plan to reflect the permanently defueled condition are evaluated pursuant to 10 CFR 50.54(q) in accordance with EN-EP-305.

VII.B CONCLUSIONS

1. Is a change to an LBD being initiated?

IF "Yes," THEN enter the appropriate change control process and include this form with the change package. (LBDCR LIC 14-14)2. Is a 10 CFR 50.59 Evaluation required?IF "Yes," THEN complete a 50.59 Evaluation in accordance with EN-LI-101 and attach a copy to the change activity.3. Is a 10 CFR 72.48 Evaluation required?IF "Yes," THEN complete a 72.48 Evaluation in accordance with EN-LI-112 and attach a copy to the change activity.Z Yes[- No Ej Yes 0 No E]Yes No EN-LI-I00 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 8 OF 52 VIII. SIGNATURES 1 Preparer: Justine Anderson/

9'I /ENVY/ Eplan/ 1/16/15 Name (print) / Signature I Company / Department

/ Date Reviewer:

Phil Couture/ Approved per telecon /ENVY/ Licensing/

2/4/15 Name (print) I Signature

/ Company I Department I Date Process Applicability Exclusion Site Procedure N/A Champion or Name (print) / Signature I Company I Department I Date Owner: Upon completion, forward this PAD form to the appropriate organization for record storage. If the PAD form is part of a process that requires transmittal of documentation, including PAD forms, for record storage, then the PAD form need not be forwarded separately.

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

If using an e-mail, attach it to this form.EN-LI-100 REV. 16 ATTACHMENT

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

VY will no longer be an Appendices Rate Estimate operating nuclear power plant. Appendix C is no longer applicable because it is based on the isotopic mix for a Loss of Coolant Accident (LOCA).Table of Contents -List of Figure 8.1 Normal On-Shift Figure 8.1 Defueled On-Shift VY will no longer be an Figures Emergency Organization Emergency Organization operating nuclear power plant. The title change reflects the permanently defueled organizational structure.

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

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

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

Table of Contents -List of Figure 8.4 Operations (Deleted)

ERO Staffing changes result Figures Support Center Emergency in one remaining OSC Organization position (OSC Manager)illustrated on the figure. A figure is no longer necessary to describe the OSC organization.

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

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

Table of Contents -List of Figure 10.1 Vermont Yankee (Deleted)

VY will no longer be an Figures Emergency Dose Rate operating nuclear power Nomogram plant. Figure 10.1 is no longer applicable because it is based on the isotopic mix for a LOCA.Section 2.0 -Definition of Alert -Events are in process or Alert -Events are in progress or Editorial revision to reflect Alert have occurred which involve an have occurred which involve an definition in NEI 99-01, Rev.actual or potential substantial actual or potential substantial 5 degradation of the level of safety degradation of the level of safety of the plant or a security event of the plant or a security event that involves probable life that involves probable life threatening risk to site personnel threatening risk to site personnel EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 11 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change or damage to site equipment or damage to site equipment because of HOSTILE ACTION. because of HOSTILE ACTION.Any releases are expected to be Any releases are expected to be limited to small fractions of the limited to small fractions of the EPA Protective Action Guideline EPA Protective Action Guideline exposure levels, exposure levels.Section 2.0 -Definition of Assessment Actions -Those Assessment Actions -Those Editorial revision to correct Assessment Actions actions which are take to actions which are taken to grammatical error effectively define the emergency effectively define the emergency situation necessary for decisions situation necessary for decisions on specific emergency on specific emergency measures.

measures.Section 2.0 -Definition of General Emergency

-Events General Emergency

-Events Editorial revision to reflect General Emergency are in process or have occurred are in progress or have occurred definition in NEI 99-01, Rev.which involve actual or imminent which involve actual or imminent 5 substantial core degradation or substantial core degradation or melting with potential for loss of melting with potential for loss of containment integrity or containment integrity or HOSTILE ACTION that results in HOSTILE ACTION that results in an actual loss of physical control an actual loss of physical control of the facility.

Releases can be of the facility.

Releases can be reasonably expected to exceed reasonably expected to exceed EPA Protective Action Guideline EPA Protective Action Guideline exposure levels offsite for more exposure levels offsite for more than the immediate site area. than the immediate site area.Section 2.0 -Definition of Hostile Action -An act toward Hostile Action -An act toward Editorial revision to reflect Hostile Action an NPP or its personnel that an NPP or its personnel that definition in NEI 99-01, Rev.includes the use of violent force includes the use of violent force 5 to destroy equipment, takes to destroy equipment, takes hostages, and/or intimidates the hostages, and/or intimidate the licensee to achieve an end. This licensee to achieve an end. This includes attack by air, land, or includes attack by air, land, or water using guns, explosives, water using guns, explosives, projectiles, vehicles, or other projectiles, vehicles, or other EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 12 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change devices used to deliver devices used to deliver destructive force. Other acts destructive force. Other acts that that satisfy the overall intent may satisfy the overall intent may be be included.

HOSTILE ACTION included.

HOSTILE ACTION should not be construed to should not be construed to include acts of civil disobedience include acts of civil disobedience or felonious acts that are not part or felonious acts that are not part of a concerted attack on the of a concerted attack on the NPP. Non-terrorism-based EALs NPP. Non-terrorism-based EALs should be used to address such should be used to address such activities, (e.g., violent acts activities, (e.g., violent acts between individuals in the owner between individuals in the owner controlled area). controlled area).Section 2.0 -Definition of Notification of Unusual Event Notification of Unusual Event Editorial revision to reflect Notification of Unusual Event -Events are in process or have -Events are in progress or have definition in NEI 99-01, Rev.occurred which indicate a occurred which indicate a 5 potential degradation of the level potential degradation of the level of safety of the plant or indicate of safety of the plant or indicate a a security threat to facility security threat to facility protection has been initiated.

No protection has been initiated.

No releases of radioactive material releases of radioactive material requiring offsite response or requiring offsite response or monitoring are expected unless monitoring are expected unless further degradation of safety further degradation of safety systems occurs. systems occurs.Section 2.0 -Definition of Site Area Emergency

-Events Site Area Emergency

-Events Editorial revision to reflect Site Area Emergency are in process or have occurred are in progress or have occurred definition in NEI 99-01, Rev.which involve an actual or likely which involve an actual or likely 5 major failures of plant functions major failures of plant functions needed for protection of the needed for protection of the public or HOSTILE ACTION that public or HOSTILE ACTION that results in intentional damage or results in intentional damage or malicious acts; (1) toward site malicious acts; (1) toward site personnel or equipment that personnel or equipment that EN-LI-100 REV. 16 ATTACHMENT

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

beyond the site boundary.Section 3.2 -1 st Paragraph, 5) Notify state authorities in 5) Notify state authorities in InForm added to the Item 5 Vermont, New Hampshire and Vermont, New Hampshire and Emergency Plan in Rev. 54.Massachusetts using the Massachusetts using the InForm Emergency Notification System. Notification System.Section 3.2 -1 st Paragraph, 7) Use the emergency

7) Use the notification plan to The Emergency Notification Item 7 notification system to notify notify appropriate personnel as System is a formal system appropriate personnel as set set forth in Figure 9.1 and Table used to notify the NRC forth in Figure 9.1 and Table 9.1. 9.1. during an emergency.

The generic use of "emergency notification system" in Step 7 can be confusing and is meant only to direct the communicator to use the notification plan set forth in Figure 9.1 and Table 9.1 of the Emergency Plan and not the Emergency Notification System. Figure 9.1 is entitled "Notification Plan" and identifies the methods used to notify various offsite agencies.Section 4.1 Vermont Yankee Nuclear Power Vermont Yankee Nuclear Power VY will no longer be an Station is located on the west Station is located on the west operating nuclear power bank of the Connecticut River bank of the Connecticut River plant. The Site Description EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 14 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. The Vermont Yankee Nuclear Power Station is a boiling water reactor having a thermal rated power of 1912 MWt. The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Entergy, with the exception of a narrow strip of land between the Connecticut River and the Vermont Yankee property for which it has perpetual rights and easements from the owner, New England Power Company.immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. The Vermont Yankee Nuclear Power Station ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). The station, shown in Figure 4.1, is located on about 125 acres in Windham County, and is owned by Entergy, with the exception of a narrow strip of land between the Connecticut River and the Vermont Yankee property for which it has perpetual rights and easements from the owner, New England Power Company.On January 12, 2015, ENO submitted a certification that a determination to permanently cease power operations was made on December 29, 2014, pursuant to 10 CFR 50.82(a)(1)(i).

ENO has submitted written certification to the NRC, in accordance with 10 CFR 50.82(a)(1) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel and placed in the Spent Fuel Pool. Upon docketing of these certifications, the 10 CFR Part 50 license for has been revised to indicate the permanently shutdown and defueled condition.

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APPLICABILITY DETERMINATION FORM PAGE 15 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change VY no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

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

Section 4.2 -2 nd Paragraph The nearest house is 1,300 feet The nearest house is 1,300 feet Editorial.

The Hinsdale from the Reactor Building and is from the Reactor Building and is Raceway no longer one of several west of the site. one of several west of the site. operates and reference is The Vernon Elementary School The Vernon Elementary School removed from the (approximate enrollment of 250 (approximate enrollment of 250 Emergency Plan.pupils) is about 1,500 feet from pupils) is about 1,500 feet from the Reactor Building.

The the Reactor Building.

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

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APPLICABILITY DETERMINATION FORM PAGE 16 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change vicinity is the Hinsdale Raceway, south of the plant. These areas located approximately three (3) have been noted since they have miles from the site. For racing required special planning events, the average attendance consideration by offsite is approximately 4,000. A authorities in the event of a nursing home is located 2 miles radiological emergency at south of the plant. These areas Vermont Yankee.have been noted since they have required special planning consideration by offsite authorities in the event of a radiological emergency at Vermont Yankee.Section 5.1 -1 st Paragraph Notification of Unusual Event Notification of Unusual Event Editorial revision to reflect definition in NEI 99-01, Rev.Events are in process or have Events are in progress or have occurred which indicate a occurred which indicate a potential degradation of the level potential degradation of the level of safety of the plant or indicate of safety of the plant or indicate a a security threat to facility security threat to facility protection has been initiated.

No protection has been initiated.

No releases of radioactive material releases of radioactive material requiring offsite response or requiring offsite response or monitoring are expected unless monitoring are expected unless further degradation of safety further degradation of safety systems occurs. systems occurs.Section 5.1 -2 nd Paragraph Notification of Unusual Event Notification of Unusual Event VY will no longer be an conditions do not cause serious conditions do not cause serious operating nuclear power damage to the plant and may not damage to the plant. The plant. A change in require a change in operational purpose of the Notification of operational status is not a status. The purpose of the Unusual Event declaration is to: consideration due to the Notification of Unusual Event 1) ensure that the first step in permanently shutdown and declaration is to: 1) ensure that any response later found to be defueled plant condition.

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

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APPLICABILITY DETERMINATION FORM PAGE 17 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change been carried out; 2) bring the state of readiness; and 3) ensure operating staff to a state of that appropriate offsite readiness; and 3) ensure that notifications have been made in appropriate offsite notifications the event that additional support have been made in the event is required.that additional support is required.Section 5.2 -1 st Paragraph Alert Alert Editorial revision to reflect Events are in process or have Events are in progress or have definition in NEI 99-01, Rev.occurred which involve an actual occurred which involve an actual or potential substantial or potential substantial degradation of the level of safety degradation of the level of safety of the plant or a security event of the plant or a security event that involves probable life that involves probable life threatening risk to site personnel threatening risk to site personnel or damage to site equipment or damage to site equipment because of HOSTILE ACTION. because of HOSTILE ACTION.Any releases are expected to be Any releases are expected to be limited to small fractions of the limited to small fractions of the EPA Protective Action Guideline EPA Protective Action Guideline exposure levels, exposure levels.Section 5.3 -1 st Paragraph Site Area Emergency Site Area Emergency Editorial revision to reflect Events are in process or have Events are in progress or have definition in NEI 99-01, Rev.occurred which involve an actual occurred which involve an actual or likely major failures of plant or likely major failures of plant functions needed for protection, functions needed for protection of the public or HOSTILE of the public or HOSTILE ACTION that results in ACTION that results in intentional damage or malicious intentional damage or malicious acts; (1) toward site personnel or acts; (1) toward site personnel or equipment that could lead to the equipment that could lead to the likely failure of or; (2) that likely failure of or; (2) that prevent effective access to prevent effective access to EN-LI-100 REV. 16 ATTACHMENT

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

beyond the site boundary.Section 5.4 -Ist Paragraph General Emergency General Emeraencv Editorial revision to reflect Events are in process or have Events are in progress or have definition in NEI 99-01, Rev.occurred which involve actual or occurred which involve actual or imminent substantial core imminent substantial core degradation or melting with degradation or melting with potential for loss of containment potential for loss of containment integrity or HOSTILE ACTION integrity or HOSTILE ACTION that results in an actual loss of that results in an actual loss of physical control of the facility, physical control of the facility.Releases can be reasonably Releases can be reasonably expected to exceed EPA expected to exceed EPA Protective Action Guideline Protective Action Guideline exposure levels offsite for more exposure levels offsite for more than the immediate site area. than the immediate site area.Figure 6.2 See "After" Column Replaced "Comm. Room" with Editorial revision to"Main TSC Area" accurately depict TSC layout.Figure 6.3 See "After" Column 0 Deleted "Radiation Protection Editorial revision to Offices" accurately depict OSC* Changed "OSC layout.Communication Center" to"OSC Manager and Briefing Room"" Deleted "Chemistry Offices"" Changed "Briefing Room" to"Rad Protection" EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 19 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change* Changed "Rad Prot" to "NCO Room"" Changed "AO Room" to"NCO Room" Figure 6.4 See "After" Column

• Deleted "HVAC Room" Editorial revision to* Added "NRC Room" accurately depict EOF/RC* Changed "Chemistry

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

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

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

By pushing one of provide updates of plant the buttons on the telephone, it conditions to NRC Region I.rings automatically at the selected location.

In the event that communications fail with the NRC due to loss of the commercial telephone system, the load dispatchers are advised that Vermont Yankee will use the Utility Microwave System to provide updates of plant conditions to NRC Region I.The Utility Radio Net is used as an alternate means of notifying load dispatchers.

Load dispatchers have 24-hour manning capability at their organizations.

The systems are tested once a week with both organizations.

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

permanently defueled status, this system is no* Core and coolant system longer necessary to transmit data, safety system parameter* Containment building data to the NRC.EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 21 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change data, NRC Memorandum from the SRadioactivity release Director, Division of dativit r s Preparedness and data, and Response (NSIR) to* Site meteorological data. Regions (Division of Reactor Vermont Yankee maintains a Projects) clarifies the continuous ERDS connection requirements for with the NRC Operations Center. maintenance and use of ERDS by licensees who have submitted certification of permanent cessation of operations pursuant to Section 50.82, "Termination of Licenses," in Part 50,"Domestic Licensing of Production and Utilization Facilities," of Title 10 of the Code of Federal Regulations, (10 CFR Part 50)." This memorandum is publicly available in ADAMS (ML14099A520).

Table 7.1: InForm added to the State Police (VT, NH, MA) 1,2 1,2,11 Emergency Plan in Rev. 54.fromCR 1,2 1,2,11 State Police (VT, NH, MA) 1,2,9 1,2,9,11 from EOF State EOCs (VT, NH, MA) 1,2,9,10 1, 2, 9,10, 11 State EOCs (VT, NH, MA) Add InForm to Table Key as #11 from EOF Section 8.1 -2 nd Paragraph During normal operations, the The minimum staff on duty at the VY will no longer be an minimum staff on duty at the plant during all shifts consists of operating nuclear power EN-LI-I00 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 22 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change plant during all shifts consists of one (1) Shift Manager, one (1)Control Room Supervisor, two (2) Control Room Operators, six (6) Auxiliary Operators, one (1)Shift Technical Advisor, one (1)Radiation Protection Technician, one (1) Chemistry Technician and security personnel as indicated in Figure 8.1. The responsibility for determining the status of the plant in an emergency is assigned to the Shift Manager or, in his absence from the Control Room, to the Control Room Supervisor who has the authority and responsibility to immediately initiate any emergency actions, including emergency classification and notification.

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

Corrective action and repair, as outlined in Table 8.4, is performed by Operations staff on-shift until supplemented by additional ERO staff.one (1) Shift Manager, one (1)Certified Fuel Handler (CFH), three (3) Non-Certified Operators (NCO), one (1) Radiation Protection Technician and security personnel as indicated in Figure 8.1. The responsibility for determining the status of the plant in an emergency is assigned to the Shift Manager or, in his absence from the Control Room, to the CFH who has the authority and responsibility to immediately initiate any emergency actions, including emergency classification and notification.

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

Corrective action and repair, as outlined in Table 8.4, is performed by Operations staff on-shift until supplemented by additional ERO staff.plant. The following on-shift positions will be eliminated: " Shift Technical Advisor (STA)" Two (2) Control Room Operators* Three (3) Auxiliary Operators* Chemistry Technician Following permanent cessation of operations and removal of fuel from the reactor vessel, Operations on-shift personnel will consist of one (1) Shift Manager (SM), one (1)Certified Fuel Handler (CFH) and three (3) Non-Certified Operators (NCOs).Title changes for the CRS to CFH and the AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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APPLICABILITY DETERMINATION FORM PAGE 23 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change These staffing levels have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

-~ 4 *1-Section 8.2 -2"' Paragraph Elements of the emergency response plan are activated subsequent to an emergency declaration by the Shift Manager;designated company personnel are notified and will report to designated locations.

The emergency response action of the personnel already present are performed on a priority basis depending on the emergency conditions and the immediate need which those conditions dictate as determined by the onshift operations crew. The specific priorities facing the emergency response forces in the various locations cannot be pre-established.

They would be specific to the nature of the emergency and variable with time as it proceeds.Elements of the emergency response plan are activated subsequent to an emergency declaration by the Shift Manager;designated company personnel are notified and will report to designated locations.

The emergency response action of the personnel already present are performed on a priority basis depending on the emergency conditions and the immediate need which those conditions dictate as determined by the on-shift operations crew. The specific priorities facing the emergency response forces in the various locations cannot be pre-established.

They would be specific to the nature of the emergency and variable with time as it proceeds.Editorial change from"onshift" to "on-shift" Section 8.2 -5"' Paragraph In emergency situations, the In emergency situations, the VY will no longer be an Shift Manager, Emergency Plant Shift Manager, Emergency Plant operating nuclear power Manager, or OSC Manager can Manager, or OSC Manager can plant and emplacement or EN-LI-100 REV. 16 ATTACHMENT

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

Therefore a prevent the following:

prevent the following:

plant trip will no longer be* Loss of important

• Loss of important applicable.

equipment, equipment, or* Personnel injury, or .Personnel injury.* Plant trip.Section 8.2.2 -1s' 5. Develop guidance for plant 5. Develop guidance for plant VY will no longer be an Paragraph, Item 5 shift operations concerning plant shift operations concerning plant operating nuclear power protection of the reactor core; protection; plant and emplacement or retention of fuel into the reactor vessel will no longer be authorized.

Therefore, the need for the Emergency Plant Manager's responsibilities to include protection of the reactor core is no longer applicable.

Section 8.2.2 -2 nd A qualified manager assumes A qualified manager assumes VY will no longer be an Paragraph the role of Emergency Plant the role of Emergency Plant operating nuclear power Manager under all emergency Manager under all emergency plant and emplacement or conditions.

To assist the conditions.

To assist the retention of fuel into the Emergency Plant Manager, the Emergency Plant Manager, the reactor vessel will no longer TSC is staffed by TSC is staffed by representatives be authorized.

Therefore, representatives from the from the following departments the need to maintain a following departments as as depicted in Figure 8.3: Reactor Engineer in the depicted in Figure 8.3:

• Operations TSC is no longer applicable.

• Operations

• Maintenance

• nMaintenance EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 25 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change* Reactor Engineering 0 Engineering

• Engineering 0 Chemistry* Chemistry (in the OSC) 0 Radiation Protection

• Radiation Protection 0 Security (stationed at the* Security (stationed at the off site command post)off site command post)Section 8.2.4 EOF Manager Deleted entire section The EOF Manager position will not exist in the Permanently Defueled ERO.Duties and responsibilities will be transferred to remaining positions within the EOF.Section 8.2.10 During implementation of Severe During implementation of Severe EPOP-TSC-3542 states that Accident Management (SAM), Accident Management (SAM), the Operations Coordinator the senior licensed individual in the Operations Coordinator in in the TSC assumes the the TSC will assume the role of the TSC will assume the role of duty of SAM Decision Decision Maker as defined in the Decision Maker as defined in Maker.SAM Guideline.

plant procedures.

Table 8.3, Page 2 of 3 Each State Health representative Each State Health representative The EOF Manager position at the EOF/RC will request at the EOF/RC will request will not exist in the monitoring updates from the monitoring updates from the Permanently Defueled ERO.EOF Manager. Lead Offsite Liaison. Duties and responsibilities will be transferred to remaining positions within the EOF.Table 8.3, Page 3 of 3 The Public Information Liaison at The Technical Advisor at the The position of Public the EOF/RC relays accident EOF/RC relays accident status Information Liaison will not status reports to the Joint reports to the Joint Information exist in the Permanently Information Center. Center. Defueled Emergency Response Organization EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 26 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change (ERO). Duties and responsibilities will be transferred to the Technical Advisor position.Table 8.4 -Page 1 of 2, Functional Area -Plant Operations

& Assessment of Operational Aspects Shift Manager (1) On Shift CRS (I) On Shift CRO (2) On Shift AO (6) On Shift STA (1) On Shift Shift Manager (1) On Shift Certified Fuel Handler (CFH) (1) On Shift Non-Certified Operator (NCO) (3) On Shift VY will no longer be an operating nuclear power plant. The following on-shift positions will be eliminated:

• STA* Two (2) Control Room Operators" Three (3) Auxiliary Operators* Chemistry Technician Following permanent cessation of operations and removal of fuel from the reactor vessel, Operations on-shift personnel will consist of the SM, one (1)CFH and three (3) NCOs.Title changes for the CRS to CFH and AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 27 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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

STA oversight and technical knowledge in this functional area will be transferred to the Shift Manager and/or the CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents previously submitted to the NRC.T able 8.4 -Page 1 of 2 ; t .V w .................

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

F ...............

I CF OnShift w ill no longer be an Functional Area -STA, oMMVIS *0 30 I OmnMeComENComNSo (1,.) 39 3m operating nuclear power so min. OtieComm.ENSComm,(2) 3 60,min..Notification/Communication; STA.,OsaeMENSC...

.. plant. The STA position will Major Tasks -Notify be eliminated.

Licensee, State, local and Following permanent federal personnel

& maintain cessation of operations, the communication Chemistry Technician Position will not be EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 28 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change responsible for performing notification/communications tasks.STA assignments in this functional area will be transferred to a CRS/CFH.This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

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

Table 8.4 -Page 1 of 2; 1EOEmergencyftor,,)

o1 ,f EOFEnergencyDirectoro(l) 1om.. I VY will no longer be an Functional Area -Shift Sq6CsSTA Tea h Shift MgrCF.H OnShift operating nuclear power Radiological Accident RStf(1). 30.= RPStaf(1) mi. plant. The STA and on-shift Assessment and Support of Chemistry Tech positions Operational Accident EN-LI-100 REV. 16 A'TACHMENT

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

STA assignments in this functional area will be transferred to the Shift Manager and/or the Control Room Supervisor.

This transfer of duties and removal of the on-shift Chemistry Tech position have been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

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

Table 8.4 -Page 1 of 2; 1 ShitRPtech (1) On Shift Fieldmonilonngtearns()

3 30 rin. This change does not Functional Area -I Fieldmonitonngteams (1)' 30 rnin. Fieldmonitoring teams 6o(r,) represent a change to the Radiological Accident Field moniton, teams1 600 1 number of on-shift RP EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 30 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Assessment and Support of Technicians.

The number of Operational Accident on-shift RP Technicians Assessment; Major Tasks -remains one (1). The Onsite (out of plant) change is intended to clarify 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; ShitChoem..Tec, (1) On Shift Chemstaff (1) 6O.n VY will no longer be an Functional Area -I rD staff,(1) 60 min. operating nuclear power Radiological Accident plant. The on-shift Assessment and Support of Chemistry Tech position will Operational Accident be eliminated.

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

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APPLICABILITY DETERMINATION FORM PAGE 31 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Table 8.4 -Page 1 of 2; 1STA (ON Shifi not needed inaPemrenuy

\/VY will no longer be an Functional Area -Plant I M30 R1 Defueled Condýon operating nuclear power System Engineering; Major plant. The STA position will Tasks -Shift Technical be eliminated.

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

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

Table 8.4 -Page 1 of 2; 1 0 Shift he Defueled Organization Functional Area -Repair & S contains three (3) NCOs on-Corrective Actions; Major shift. This on-shift Tasks -Mechanical complement has been Maintenance evaluated in the VY analysis of proposed post-shutdown EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 32 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

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

Table 8.4 -Page 1 of 2;Functional Area -Repair &Corrective Actions; Major Tasks -Rad Waste Operator IA01CRO (1) 10m FNCO 0 The CRO position is eliminated in the post-shutdown condition.

The Defueled Organization consists of three (3) NCOs on-shift.

This on-shift complement has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 33 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change condition.

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

Table 8.4 -Page 1 of 2;Functional Area -Repair &Corrective Actions; Major Tasks -Electrical Maintenance/Instrumentation

& Control Technician Shift AO (1*) On Shift Maintenance (1) 30 mi.Mainenance (1) 60 (Fn NCO(1-) On Shift Maintenance (1) 30 min-Maintenance (1) [60 min.The Defueled Organization consists of three (3) NCOs on-shift.

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

Title change for the AO to NCO was dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that replaced EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 34 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

Table 8.4 -Page 2 of 2; ShfAo 2-) 2 On NCO(2-) On Shif The Defueled Organization Functional Area -Protective RP (2) 30 min RP (2) 30 mi consists of three (3) NCOs RP (2) 60 min .RP (2) .60 mnin Actions (In Plant); Major on-shift.

This on-shift Tasks -Radiation complement has been Protection, access control, evaluated in the VY analysis HP, coverage for repair, of proposed post-shutdown corrective actions, search & on-shift staffing in rescue, first aid & firefighting, conjunction with the personnel monitoring, postulated accidents that dosimetry will be applicable in the permanently defueled condition.

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

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APPLICABILITY DETERMINATION FORM PAGE 35 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Table 8.4, Note **** May be performed by Deleted VY will no longer be an engineering aide to Shift operating nuclear power Manager (STA for ENVY) plant. The STA position will be eliminated.

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

Table 8.4, Note 1 AP 0894 specifies minimum shift AP 0894 specifies minimum shift The Defueled on-shift staffing requirements.

FB staffing requirements.

FB staffing has been evaluated requires 5 persons per TRM and requires 5 persons per TRM and in the VY analysis of the Vermont Yankee Nuclear the Vermont Yankee Nuclear proposed post-shutdown on-Power Station On-Shift Staffing Power Station Analysis of shift staffing in conjunction Analysis.

The staffing analysis is Proposed Post-Shutdown with the postulated maintained as a controlled On-Shift Staffing.

The staffing accidents that will be document and is effective 30 analysis was evaluated to reflect applicable in the days after OSRC approval.

STA VY's permanently shutdown and permanently defueled and Chemistry Tech must be defueled conditions, including condition.

available within 10 minutes to the on-shift staff composition and the Control Room. VY letter to revised accident analyses.NRC dated 4/14/1981 (FVY 81-65) establishing position.

VY letter to NRC 6/22/1982 (FVY 82-75) Supplement -NUREG 0737 Item III.A.1.2 on training of EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 36 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change on-shift staff to support VY position for staffing.

VY letter to NRC 4/14/1981 (FVY 81-65) TMI Action Plan Item II1.A.1.2, goal for augmentation of staff. VY letter to NRC 6/15/82 (FVY 82-70) Results of Augmentation drills to support use of goals.Titles of ENVY ERO positions are shown.Table 8.4, Note 2 All AOs use digital dosimeters with features for dose rate and total dose monitoring.

AOs are trained to self-monitor in an emergency.

All NCOs use digital dosimeters with features for dose rate and total dose monitoring.

NCOs are trained to self-monitor in an emergency.

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

Table 8.4, Note 3 ENVY has designated pager ENVY has designated ERO The Defueled Organization holders who staff positions members who staff positions will consist of fewer than 4 required to meet minimum required to meet minimum teams rotating ERO duty.staffing to activate TSC, OSC staffing to activate the TSC, OSC Additional changes to this and EOF (see E Plan Figures and EOF. The minimum staff note are editorial to remove 8.3 through 8.5). There are a positions required to activate the references to pagers and minimum of 4 persons per TSC and EOF are shown in E pager holders.position (4 teams who rotate Plan Figures 8.3 and 8.5. The duty). However, all persons on OSC Manager is the only EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 37 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change teams are expected to respond. position required to activate and In addition, all other ERO staff the OSC. All ERO personnel not on pagers are personnel are expected to notified by the emergency call-in respond when notified by the notification system and are emergency call-in notification expected to respond. system.Table 8.4, Note 4 The on-shift Shift Manager, CRS, STA, and Chem Tech have the capability to do initial dose assessment and PAR. The TSC and EOF radiation assessment staff relieves them of this function.The on-shift Shift Manager and CFH have the capability to do initial dose assessment and PAR. The TSC and EOF radiation assessment staff relieves them of this function.VY will no longer be an operating nuclear power plant. The STA and on-shift Chemistry Technician positions will be eliminated.

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

CFHs will supervise fuel handling operations in the permanently defueled condition.

The CRS and SM will be qualified as CFHs.However, the SM requires additional qualification beyond the CFH training.Therefore, any reference to EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 38 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change the CFH position throughout this Plan is considered to be equivalent to the CRS position.

NCOs will perform duties typically associated with those performed by Auxiliary Operators and Control Room Operators, such as manipulation and monitoring of plant equipment.

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

positions will be eliminated: " Shift Technical Advisor 0 STA* Chem Tech 0 Two (2) Control Room" Control Room Operators Operators 0 Three (3) Auxiliary Replaced "Control Room Operators Supervisor" with "Certified Fuel 0 Chemistry Technician Handler" Following permanent Replaced "Auxiliary Operators" cessation of operations and with "Non-Certified Operator" removal of fuel from the reactor vessel, Operations on-shift personnel will consist of the SM, one (1)CFH and three (3) NCOs.Title changes for the CRS to CFH and AO and CRO to NCO were dependent upon NRC approval of proposed changes to the VY EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 39 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Technical Specifications (BVY 13-096) that replaced references to licensed and non-licensed operators with references to CFHs and NCOs. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

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

STA oversight and technical knowledge in this functional area will be transferred to the Shift Manager and/or the CRS/CFH. This transfer of duties has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents previously submitted to the NRC..Figure 8.2 VY Emergency Management Replaced figure with "VY The positions of EOF Organization Defueled Emergency Manager and TSC Manager will not exist in the EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 40 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Management Organization" Permanently Defueled ERO.Deleted the following positions:

Duties and responsibilities will be transferred to" EOF Manager remaining positions within* TSC Manager each Emergency Response Facility.Figure 8.3 Technical Support Center Replaced figure with "Defueled The TSC positions identified Emergency Organization Technical Support Center for deletion will not exist in Emergency Organization" the Permanently Defueled Deleted the following positions:

ERO. Duties and responsibilities will be" TSC Manager transferred to remaining* TSC Communicator positions within the TSC." Mechanical Engineer* Reactor Engineer" Electrical

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

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

ERO. Duties and responsibilities will be* EOF Manager transferred to remaining* EOF Communicator positions within the EOF.* Public Information Liaison* EOF Log Keeper* IT Specialist EN-LI-100 REV. 16 ATTACHMENT

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

ERO. Duties and responsibilities will be 0 Information Coordinator transferred to remaining 0 Technical Assistant positions within the JIC.0 Credentialing

• Press Release Writer 0 Logistics Coordinator 0 Inquiry Response Coordinator

• Media Monitoring 0 JIC Log Keeper* Inquiry Responders Section 9.2.1 -2nd 3. The Shift Technical Advisor Deleted VY will no longer be an Paragraph reports to the Control Room operating nuclear power and provides technical plant. The STA position will support as necessary; be eliminated.

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

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

Section 9.2.2 5. The EOF Manager 5. The Emergency Director The EOF Manager position EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 42 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change establishes operations in the establishes operations in the will not exist in the EOF/RC; EOF/RC; Permanently Defueled ERO.Duties and responsibilities will be transferred to remaining positions within the EOF.Section 9.2.4 -2 nd 1. The Emergency Director may 1. The Emergency Director may The EOF Manager position Paragraph request that the EOF request that other personnel will not exist in the Manager mobilize other be mobilized in support of Permanently Defueled ERO.personnel in support of Vermont Yankee through Duties and responsibilities Vermont Yankee through activation of the Corporate will be transferred to activation of the Corporate Emergency Center. remaining positions within Emergency Center. the EOF.Section 9.3 -3 r' Paragraph De-escalation from a Notification De-escalation from a Notification VY will no longer be an of Unusual Event to a recovery of Unusual Event to a recovery operating nuclear power phase requires satisfying the phase requires satisfying the plant and emplacement or following criteria:

following criteria:

retention of fuel into the 1. Criticality controls are in 1 .Criticality controls are in reactor vessel will no longer 1.eCrftecotcait cbe authorized.

Therefore, effect; effect; the need for adequate core 2. The core is being adequately

2. The fission product release cooling, control over cooled; has been controlled; containment pressure and 3. The fission product release 3. An adequate heat transfer temperature and control of has been controlled; path to an ultimate heat sink reactor coolant system 4. Control has been established has been established; pressure is not necessary.

over containment pressure 4. Notification of Unusual Event and temperature; conditions have been 5. An adequate heat transfer reviewed, are under control, path to an ultimate heat sink and are not expected to pathto n utimae hat ink deteriorate further.has been established;

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

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APPLICABILITY DETERMINATION FORM PAGE 43 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change and/or 7. Notification of Unusual Event conditions have been reviewed, are under control, and are not expected to deteriorate further.Table 9.1, Technical Support Emergency Plant Manager Emergency Plant Manager The TSC positions identified Center; Alert or Site Area TSC Manager Maintenance Coordinator for deletion will not exist in Emergency or General (Electdcal/MechanicaVI&C) the Permanently Defueled Emergency Column Maintenance Coordinator ERO. Duties and (Electrical/MechanicaVl&C)

Radiological Coordinator responsibilities will be Radiological Coordinator Engineering Coordinator(Project, transferred to remaining Reactor Engineer System, Design) positions within the TSC.Engineering Coordinator(Project, Operations Coordinator System, Design)Operations Coordinator Engineering Support Group Table 9.1, Operations OSC Manager OSC Manager VY will no longer be an Support Center; Alert or Site Radiation Protection Staff Radiation Protection Staff operating nuclear power Area Emergency or General plant. Use of the term Emergency Chemistry Staff Chemistry Staff "licensed" is no longer Spare Licensed Operators Spare AOs/CROs/NCOs appropriate.

Spare Auxiliary Operators Control Instrument Specialists The OSC positions identified for deletion will not exist in Control Instrument Specialists Plant Mechanics the Permanently Defueled Plant Mechanics ERO. Duties and responsibilities will be transferred to remaining positions within the OSC.Table 9.1, Emergency Emergency Director Emergency Director The EOF positions identified EN-LI-100 REV. 16 ATTACHMENT

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

• Site/Offsite Monitoring Teams Personnel

& Equipment Monitor*Site/Offsite Monitoring Teams Public Information Liaison Table 9.1, Joint Information Company Spokesperson Company Spokesperson The JIC positions identified Center; Alert or Site Area VY Public Information Staff for deletion will not exist in Emergency or General the Permanently Defueled Emergency Nuclear Public Information ERO. Duties and Representatives responsibilities will be Joint Information Center Staff transferred to remaining positions within the JIC.Section 10.1.1 10.1.1 Initial offsite Radiological Dose Deleted The Unified Rascal Interface Projection Capability (URI) will become the Vermont Yankee has developed primary site specific dose a method to quickly determine assessment software for the projected offsite radiological Vermont Yankee. This conditions at various distances computer program replaces downwind of the plant site. the existing ODPS and During the initial stages of an METPAC dose assessment emergency, the Shift Manager or software.designated individual is responsible to perform the initial evaluation of offsite radiological conditions.

The initial evaluation EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 45 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change of offsite radiological conditions is accomplished by utilizing the Offsite Dose Projection System (ODPS).The ODPS utilizes a straight line Gaussian plume dispersion model programmed on the plant process computer.

The program allows the user the option to select one of two release pathways (elevated or ground)and to utilize site-specific radiological and meteorological information to estimate the Total Effective Dose Equivalent and adult thyroid Committed Dose Equivalent (elevated release only) at a distance of 0.35 miles to 10 miles from the plant site.Section 10.1.2 Once the EOF/RC is activated, Vermont Yankee utilizes a plume tracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiological accident conditions.

The system assumes a Gaussian, variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Station site. Both continuous and intermittent releases for either ground or stack release points can be evaluated.

The effects of release height, building wake Vermont Yankee utilizes a plume tracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiological accident conditions.

The system assumes a variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Station site. Both continuous and intermittent releases for either ground or stack release points can be evaluated.

The effects of release height, buildinR wake entrainment, The Unified Rascal Interface (URI) will become the primary site specific dose assessment software for Vermont Yankee. This computer program replaces the existing ODPS and METPAC dose assessment software.

This section is revised to describe URI.v -v EN-LI-100 REV. 16 ATTACHMENT

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APPLICABILITY DETERMINATION FORM PAGE 46 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change entrainment, momentum plume rise, precipitation and terrain height can be assessed in the evaluation.

Plume trajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.The model combines complex plume transport algorithms with the same dose assessment algorithms used by the model described in Section 10.1.1.The model is programmed on a personal computer.

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

rally, the Offsite Dose Nomogram can be used to determine an activity release rate (l.Ci/sec) and a projected offsite whole body plume centerline dose rate (mR/hr) at 1/3 of a mile from the stack.These determinations are made by using Figure 10.1 with the following additional information:

after reactor shutdown;ilant stack high range monitor response;ilant stack flow rate at the time of the accident; and speed.The assumptions incorporated in and the use of the nomograms contained in momentum plume rise, precipitation and terrain height can be assessed in the evaluation.

Plume trajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.The model combines complex plume transport algorithms with dose assessment algorithms.

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

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APPLICABILITY DETERMINATION FORM PAGE 47 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Figure 10.1 is discussed in Appendix C.Section 10.2 -1 st Paragraph In the event a General In the event a General VY will no longer be an Emergency has been declared, Emergency has been declared, operating nuclear power Vermont Yankee immediately Vermont Yankee immediately plant and emplacement or recommends protective actions recommends protective actions retention of fuel into the to state authorities based on to state authorities based on reactor vessel will no longer plant conditions which include plant conditions.

At a minimum, be authorized.

Therefore, the status of core and the Shift Manager or Emergency the need to communicate containment conditions.

At a Director, who is in charge of the the status of the core and minimum, the Shift Manager or emergency response activities, containment conditions is Emergency Director, who is in recommends that the general not necessary.

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

Therefore, an evacuation of the towns of Vernon, Vermont; and all towns accident involving the Hinsdale, New Hampshire and located five miles downwind in reactor the potential for Vernon, Vermont; and all towns the affected sectors. actual or projected located five miles downwind in substantial core damage no the affected sectors. longer exists.Section 10.3- 2nd Paragraph Table 10.2 specifies the Table 10.2 specifies the VY will no longer be an guidelines on emergency dose guidelines on emergency dose operating nuclear power limits for personnel providing limits for personnel providing plant. The on-shift EN-LI-100 REV. 16 ATTACHMENT

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

Environmental Protection Environmental Protection Agency Emergency Worker Agency Emergency Worker Dose Limit Guides (EPA Dose Limit Guides (EPA 400-R-92-001).

The Shift 400-R-92-001).

The Shift Manager initially has the Manager initially has the responsibility to authorize responsibility to authorize emergency dose commitments emergency dose commitments until relieved by the Emergency until relieved by the Emergency Plant Manager. This Plant Manager. This authorization is coordinated with authorization is coordinated with the assistance of the the assistance of the Radiological Coordinator or Shift Radiological Coordinator and Chemistry and Radiation Radiation Protection Technicians Protection Technicians as as needed. Exposure to needed. Exposure to individuals individuals providing emergency providing emergency functions functions will be consistent with will be consistent with the limits the limits specified in Table 10.2 specified in Table 10.2 with with every attempt made to keep every attempt made to keep exposures ALARA.exposures ALARA.Section 10.5.1 Medical Response Team Medical response is provided by The Medical Response members are trained in on-shift Fire Brigade members Team is being eliminated.

accordance with station trained in basic first-aid and Medical response will be procedures.

Cardiopulmonary resuscitation provided by Fire Brigade (CPR). members available on site on a 24-hour per day basis.Section 10.6 A range of protective actions to A range of protective actions to Revised to reflect important protect onsite personnel during protect onsite personnel during equipment during hostile action is provided to hostile action is provided to permanently shutdown and ensure the continued ability to ensure the continued ability to defueled plant condition.

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

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 49 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change emergency plan. and perform the functions of the emergency plan.Figure 10.1 Figure 10.1 Vermont Yankee Deleted Figure VY will no longer be an Emergency Dose Rate operating nuclear power Nomogram plant. Figure 10.1 is no longer applicable because it is based on the isotopic mix for a LOCA.Section 11.3 -4th Paragraph The Public Information Liaison The Technical Advisor and The Technical Advisor will and required staff report to the required staff report to the assume this duty in the EOF/RC for coordinating the EOF/RC for coordinating the permanently defueled accident information between the accident information between the condition.

plant and the Joint Information plant and the Joint Information Center. Center.Section 11.3- 6 h Paragraph Normally, a prerecorded Normally, a prerecorded VY will no longer be an message provides, on a daily message provides, on a daily operating nuclear power basis, routine operating basis, routine plant information, plant.information, changes in plant changes in plant conditions, and operation, and other items of other items of interest.interest.Section 12.1.4 -Medical To evaluate the training of the To evaluate the training of the The Medical Response Drills facility's medical response team facility's medical response and Team is being eliminated.

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

Appendix B (A more detailed listing of (A more detailed listing of Editorial revision to emergency equipment is emergency equipment is procedure number.provided in OP 3506, provided in OP-EQUIP-3506,"Emergency Equipment "Emergency Equipment Readiness Check") Readiness Check")EN-LI-100 REV. 16 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 50 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Appendix C Appendix C Initial Offsite Dose Appendix deleted in its entirety VY will no longer be an Rate Estimation operating nuclear power plant. Appendix C is no longer applicable because it is based on the isotopic mix for a Loss of Coolant Accident (LOCA).Appendix G -Section I OP-3507 EPOP-EREC-3507 Editorial revision to OP-3508 EPOP-MED-3508 procedure numbers.OP-3510 EPOP-OSMT-3510 OP-3513 EPOP-RAD-3513 OP-3547 EPOP-SEC-3547 OP-3548 EPOP-TERM-3548 AP-3712 EPAP-TRNG-3712 Appendix G -Section I Not Applicable Add: See below.V-EN-FAP-EP-009, Use of KI for the Emergency Response Organization V-EN-FAP-EP-010, Severe Weather Response V-EN-FAP-EP-012, Severe Weather Recovery V-EN-EP-202, Equipment Important to Emergency Preparedness V-EN-EP-301, Emergency Planning Assessment of Offsite Emergency Response Capability EN-LI-100 REV. 16 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 51 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Following a Natural Disaster V-EN-EP-305, Emergency Planning 10CFR50.54(q)

Review Program V-EN-EP-306, Drills and Exercises V-EN-EP-307, Hostile Action Based Drills & Exercises V-EN-EP-308, Emergency Planning Critiques V-EN-EP-310, Emergency Response Organization Notification System V-EN-EP-401, Public Use of Emergency Preparedness Owner Controlled Area V-EN-EP-601, Corporate Emergency Center Operations V- EN-EP-801

-Emergency Response Organization Appendix G -Section I Not Applicable Add: EPOP-AFA-10083 was EPOP-AFA-10083

-Alternative developed and added to the EPciyAciatn Emergency Plan for Facilityi Activation compliance with 10 CFR EPOP-URI-10095-Offsite Dose Part 50, Appendix E Section Assessment using the Unified IV.E.8.d.Rascal Interface EPOP-URI-1 0095 was developed and added to the Emergency Plan to address the change to URI.EN-LI-100 REV. 16 ATTACHMENT

9.1 PROCESS

APPLICABILITY DETERMINATION FORM PAGE 52 OF 52 Emergency Plan Section Before (Rev. 54) After Reason for Change Appendix G -Corporate Support Procedures CorDorate SUDDort Procedures I Deletedl l lEN-EP-311 will be deleted.VY will no longer be an operating nuclear power plant.Section VI.1 of Appendix E to 10 CFR Part 50 indicates that ERDS is not applicable to nuclear power facilities that are shut down. Based on the permanently defueled status, this system is no longer necessary to transmit safety system parameter data to the NRC.The applicable information from the remaining procedures will be relocated to a VY-specific procedure and added to the EPIP list (see above) and the Corporate Support Section of Appendix G will be deleted.EN-EP-309 and EN-EP-606 will be deleted as neither procedure is applicable to VY. These procedures should not have been included in the VY Emergency Plan and removal is an editorial change.EN-LI-100 REV. 16 A'n'ACHMENT 9.1 IOCFR50.64(q)

SCREENING Procedure/Document Number. Emergency Plan Revision:

55 Page 1 of 10 Equipment/Facility/Other.

Vermont Yankee Title: Vermont Yankee Emergency Plan Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the Implementation of the emergency plan): Table of Contents" Editorial revision to reflect changes to section tItles and page numbers described below* Removed Appendix C from the Table of Contents" Removed Figure 10.1 from the Table of Contents Section 2.0. Definitions

• Changed 'process" to "progress' in the following definitions to conform with definitions contained In NEI 99-01,'Methodology for Development of Emergency Action Levels', Rev. 5, dated February 2008: " Alert* General Emergency" Notification of Unusual Event" Site Area Emergency" Changed 'take" to 'taken" in the definition of Assessment Actions" Changed "Intimidates*

to 'Intimidate" in the definition of Hostile Action Section 3.2. Actions In an Emergencv* Changed 'Emergency Notification System" to "InForm Notification System' In step 5" Changed "emergency notification system" to "notification plan" in step 7 Section 4.1. The Site* Revised the 2e Paragraph to address January 12, 2015 certification of permanent cessation of operations and permanent removal of fuel from the reactor vessel Section 5.1. Notification of Unusual Event" Changed 'process" to 'progress"* Removed "and may not require a change In operational status"* Changed "process" to "progress" Section 5.3. Site Area Emeraencv* Changed "process' to "progress" Section 5.4. General Emeraencv* Changed "process" to "progress" Figure 6.2. Technical Suonort Center Layout* Replaced figure with figure accurately depicting TSC layout Flours 6.3. Ooerational Sucoort Center Layout* Replaced figure with figure accurately depicting OSC layout Fioure 6.4. Emeroencv Ooerations Facilitv/Recoverv Center LaYout 0 Replaced figure with figure accurately depicting EOF/RC layout Section 7.3. Utility Microwave and Radio Systems* Removed, "The Utility Microwave Is a line of sight dedicated system used to notify system load dispatchers of emergency conditions at the plant. The telephone has buttons marked for each load dispatcher.

By pushing one of the buttons on the telephone, it rings automatically at the selected location."* Removed "the'* Removed "The Utility Radio Net is used as an alternate means of notifying load dispatchers.

Load dispatchers have 24-hour manning capability at their organizations.

The systems are tested once a week with both organizations." EN-EP-305 REV 3 AI"rACHMENT 9.1 IOCFR50.54(q)

SCREENING ATTACHMENT

.1110F55(a CENN SProcedure/Document Number: Emergency Plan Revision:

55 Page 2 of 10 EquipmentlFacillty/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan Section 7.10. EmemencW Resoonse Data System (Deletion addressed in seoarate 50.54(a) screenino and analvsisl a Deleted Section Table 7.1. Vermont Yankee Emergencv Communications Matdx* Added "11" (InForm) to the following:

a Calling From: CR and EOF Calling To: State Police (VT, NH, MA)* Calling From: CR and EOF Calling To: State EOCs (VT, NH, MA)* Added "11 InForm" to the Key Section 8.2. Emergency Response Oeanilzation

• Changed "onshit" to "on-shift"* Deleted "Plant trip" bullet Section 8.2.10. Decision Maker* Replaced "the senior licensed individual In the TSC will assume the role of Decision Maker as defined in the SAM Guideline" with "the Operations Coordinator In the TSC will assume the role of Decision Maker as defined in plant procedures' Section 10.5.1. Medical Treatment* Replaced, "Medical Response Team members are trained in accordance with station procedures." with"Medical response Is provided by on-shift Fire Brigade members trained In basic first-aid and Cardiopulmonary resuscitation (CPR)." Section 10.1.1. Initial Offsfte RadloloaicaL Dose Proiection Caoabilitv

• Deleted Section Section 10.1.2. Vadable Tralectorv Atmospheric Disoerlon* Removed, "Once the EOF/RC Is activated," in the first sentence of first paragraph" Removed "Gaussian," In the second sentence of first paragraph" Removed, "the same" in first sentence of second paragraph" Removed, "used by the model described In Section 10.1.1" in first sentence of second paragraph" Deleted third and fourth paragraph Section 10.8. Protective Actions for Onsite Personnel* Replaced, "safely shut down the reactor" with "maintain equipment Important to safe storage of spent fuel" Floure 10.1. Vermont Yankee Emeroencv Dose Rate Nomogram* Deleted figure Section 11.3. Public Information

• Replaced, "routine operating Information, changes in plant operation" with "routine plant Information, changes in plant conditions" Section 12.1.4. Medical Drill 0 Replaced, "To evaluate the training of the facility's medical response team and offsite..." with "To evaluate the training of the facility's medical response and offslte..." Appendix B. Ememencv Eouioment a Changed procedure number from "OP 3506" to "EPOP-EQUIP-3506" Aooendix C. Initial Offsite Dose Rate Estimation

• Deleted Appendix EN-EP-305 REV 3 AI~rAciwENT 9.1 10CFR50.54(q)

SCREENING Procedure/Document Number: Emergency Plan Revision:

55 Page 3 of 10 EquipmentlFacilltylOther:

Vermont Yankee Title: Vermont Yankee Emergency Plan Acoendlx G. Index of Emergencv Plan Imolementino Procedures and Supoort Plans" Revised the following procedure numbers:* OP 3507 to EPOP-EREC-3507

• OP 3508 to EPOP-MED-3508

• OP 3510 to EPOP-OSMT-3510

• OP 3513 to EPOP-RAD-3513" OP 3547 to EPOP-SEC-3547

• OP 3548 to EPOP-TERM-3548

• AP 3712 to EPAP-TRNG-3712

• New procedure EPOP-AFA-1 0083, Alternative Facility Activation, was added to the Emergency Plan to comply with new EP rulemaldng and 10 CFR Part 50, Appendix E Section IV.E.8.d." New procedure EPOP-URI-100g5, Offsite Dose Assessment using the Unified Rascal Interface, was added to the Emergency Plan to address the URI change" Moved the following procedures from Section II, Support Plans, Corporate Support Procedures to Section I, Emergency Plan Implementing Procedures and revised the numbering format from EN-EP-xxx to V-EN-EP-xxx: " V-EN-FAP-EP-009, Use of KI for the Emergency Response Organization" V-EN-FAP-EP-010, Severe Weather Response" V-EN-FAP-EP-012.

Severe Weather Recovery V-EN-EP-202, Equipment Important to Emergency Preparedness

• V-EN-EP-301, Emergency Planning Assessment of Oftsite Emergency Response Capability Following a Natural Disaster" V-EN-EP-305, Emergency Planning 1 OCFR50.54(q)

Review Program* V-EN-EP-306, Drills and Exercises* V-EN-EP-307, Hostile Action Based Drills & Exercises* V-EN-EP-308.

Emergency Planning Critiques* V-EN-EP-310, Emergency Response Organization Notification System* V-EN-EP-401, Public Use of Emergency Preparedness Owner Controlled Area* V-EN-EP-601, Corporate Emergency Center Operations

• V-EN-EP-801.

Emergency Response Organization" Deleted EN-EP-31 1, Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN) from Section II, Support Plans, Corporate Support Procedures" Deleted EN-EP-309, Fatigue Management for Hurricane Response Activities and EN-EP-606, Pandemic Flu Response from Section II, Support Plans, Corporate Support Procedures" Deleted Section II, Support Plans, Corporate Support Procedures References to Control Room Supervisor (CRS). Control Room Operator (CR)O. and Auxiliary Ooerators (AO)* Throughout the Emergency Plan, references to Control Room Supervisor (CRS), Control Room Operator (CRO) and Auxiliary Operators (AOs) have been replaced with Certified Fuel Handler (CFH) and Non-Certified Operators (NCOs). Specifically, Section 8.1, Table 8.4, and Figures 6.3 and 8.1. Emergency Plan changes submitted in BVY 14-018 stated, "Title changes for the CRS and CRO/AC to CFH and NCO, respectively, are dependent upon NRC approval of proposed changes to the VY Technical Specifications (BW 13-098) that revise the minimum shift staffing requirements in the VY Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs. The Emergency Plan submitted in BVY 14-018 addressed the pending title changes by referring to titles as "CR5/CFi" and AO/CROINCO" and included Note .... In Table 8.4 Indicating title changes were dependent on NRC approval of BVY 13-096. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).

EN-EP-305 REV 3 ATTACHMENT 9.1 10CFR50-54(Q)

SCREENING Procedure/Document Number-. Emergency Plan I elslon: 55 Page 4 of 10 e Equlpment/Facillty/Other Vermont Yankee Title: Vermont Yankee Emergency Plan Part II. Activity Previously Reviewed?

ElYES 0 NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.64(q)(3)

Continue to Evaluation Is next part Alert and Notification System Design Report? NOT required.Enter If YES, Identify bounding source document number/approval reference and justmfcatlon ensure the basis for concluding the source document fully bounds the proposed bel and change is documented below: complete Part Vl.Justification:

[0 Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-1 00)NOTE: For example, when a design change Is the proposed activity, consequential actions may Include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

APPLICABILITY CONCLUSION 0 If there are no controlling change processes, continue the 50.54(q)(3)

Screening.

0 One or more controlling change processes are selected, however, some portion of the activity Involves the emergency plan or affects the implementation of the emergency plan: continue the 50.54(q)(3)

Screening for that portion of the activity.

Identify the applicable controlling change processes below.o One or more controlling change processes are selected and fully bounds all aspects of the activity.

50.54(q)(3)

Evaluation Is NOT reaulred.

Identify controllina chanue orocesses below and comolete Part VI.CONTROLLING CHANGE PROCESSES 10 CFR 50.54(q)Part IV. Editorial Change [:]YES ONO 50.54(qX3)

Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is pat numbering, spelling, or punctuation that does not change intent? NOT required.Justification:

Ene justification and complete Pan A portion of the changes described in Part I are editorial or typographical vi.changes. These changes are addressed in Part V of this screening.

I I Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets)

Does this activity affect any of the following, Including program elements from NUREG-0654/FEMA REP-1 Section I1?1. Responsibility for emergency response Is assigned.

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

In accordance with the emergency plan. (11 3. The process ensures that on shift emergency response responsibilities are staffed and assigned.

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

[2] Q1 5. Arrangements for requesting and using off site assistance have been made. (3] 0]6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [33 J]7. A standard scheme of emergency classification and action levels Is in use. [4] " 0 8. Procedures for notification of State and local governmental agencies are capable of alerting them of []the declared emergency within 15 minutes after declaration of an emergency and providing follow-EN-EP-305 REV 3 AIrrACHMENT 9.1 10CFR60.54(q)

SCREENING SProcedure/Document Number: Emergency Plan Revision:

55 Page 5 of 10 EquipmentlFacllltylOther.

Vermont Yankee Title: Vermont Yankee Emergency Plan up notifications.

[5)9. Administrative and physical means have been established for alerting and providing prompt Instructions to the public within the plume exposure pathway. [5]10. The public ANS meets the design requirements of FEMA-REP-1 0, Guide for Evaluation of Alert and El Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]11. Systems are established for prompt communication among principal emergency response organizations.

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

[8]13. Emergency preparedness Information Is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). [7]14. Coordinated dissemination of public Information during emergencies Is established.

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

(8]18. Adequate equipment is maintained to support emergency response.

[8] El 17. Methods, systems, and equipment for assessment of radioactive releases are in use. (9]18. A range of public PARs is available for Implementation during emergencies.

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

(101 20. A range of protective actions is available for plant emergency workers during emergencies, Including those for hostile action events.[1 0]21. The resources for controlling radiological exposures for emergency workers are established.

[1111 22. Arrangements are made for medical services for contaminated, Injured individuals.

[12]23. Plans for recovery and reentry are developed.

[13] L1 24. A drill and exercise program (including radiological, medical, health physics and other program areas) Is established.

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

[14]28. Identified weaknesses are corrected.

[14] U 27. Training Is provided to emergency responders.

[15]28. Responsibility for emergency plan development and review is established.

[16]29. Planners responsible for emergency plan development and maintenance are properly trained. (1]APPLICABILITY CONCLUSION 0 If no Part V criteria are checked, a 50.54(q)(3)

Evaluation Is NOT required; document the basis for conclusion below and complete Part VI.I if any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3)

Evaluation.

BASIS FOR CONCLUSION Editorial Chanages The following editorial changes require no further evaluation.

The Table of Contents has been revised to address updated page numbers and the deletion of Section 7.10 EN-EP-305 REV 3 ATTrACHMENT 9.1 10CFRSO.54(a)

SCREENING Procedure/Document Number: Emergency Plan /Rvision:

55 Page 6 of 10 E Equlpment/FacilltyiOther:

Vermont Yankee Title: Vermont Yankee Emergency Plan (Emergency Response Data System), Section 10.1.1 (Initial Offsite Radiological Dose Projection Capability), Figure 10.1 (Vermont Yankee Emergency Dose Rate Nomogram) and Appendix C (Initial Ofisite Dose Rate Estimation).

These changes do not change the meaning or Intent of the Emergency Plan, change any facilities or equipment, or change any of the processes described in the Emergency Plan. Updates to the Table of Contents to match the body of the Emergency Plan are administrative in nature and no further evaluation is required.Changes to the definitions of Alert, General Emergency, Notification of Unusual Event, Site Area Emergency and Hostile Action in Section 2.0 (Definitions) and sections 5.1 (Notification of Unusual Event), 5.2 (Alert), 5.3 (Site Area Emergency) and 5.4 (General Emergency) are editorial changes to duplicate the definitions with those In NEI 99-01, "Methodology for Development of Emergency Action Levels," Rev. 5; on which the VY EALs are based. No further evaluation is required with respect to these changes.The change to the definition of Assessment Actions in section 2.0 is an editorial change and no further evaluation Is required.The change to Item 7 In Section 3.2 is an editorial change. The Emergency Notification System Is a formal system used to notify the NRC during an emergency.

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

No further evaluation is required with respect to this change.The change to Section 4.1 to address the January 12, 2015 certification is an editorial change. No further evaluation Is required with respect to this change.The changes to Figures 6.2 and 6.4 are administrative In nature and reflect accurate facility layout. This revision does not change any facilities or equipment.

No further evaluation is required.The change from "onshift" to "on-shift" In Section 8.2 Is an editorial change for consistency with the remainder of the Emergency Plan. No further evaluation is required with respect to this change. Currently, Section 8.2.10 of the VY Emergency Plan identifies the senior licensed individual in the TSC as assuming the role of Decision Maker during implementation of Severe Accident Management (SAM). Section 2.3 of Attachment 3 (Operations Coordinator) of EPOP-TSC-3542 instructs the Operations Coordinator in the TSC to assume the duty of the SAM Decision Maker if it is determined that the emergency requires implementation of SAM. Revision of the Emergency Plan to refer to the Operations Coordinator in the TSC and to plant procedures rather than the senior licensed individual in the TSC and the SAM Guideline is editorial in nature and no further evaluation Is required with respect to this change.Appendix B: The revision to Appendix B, "Emergency Equipment," of the Site Emergency Plan to update procedure number OP 3506 to EPOP-EQUIP-3506 does not impact any of the 10 CFR 50.47(b) planning standard functions or program elements listed in Part V of this form. Reference to these documents is administrative In nature and no further evaluation is required.Appendix G: The revisions to Appendix G, "Index of Emergency Plan Implementing Procedures and Support Plans," of the Site Emergency Plan to document relocation of VY-specific Information from Corporate Procedures in Section II to VY-speclfic procedures in Section I does not Impact any of the 10 CFR 50.47(b) planning standard functions or program elements listed in Part V of this form. Additionally, the addition of new procedure EPOP-AFA-10083, Alternative Facility Activation, was added to the Emergency Plan to comply with new EP rulemaking and 10 CFR Part 50, Appendix E Section IV.E.8.d.

EN-EP-309, Fatigue Management for Hurricane Response Activities, and EN-EP-606, Pandemic Flu Response, are not applicable to VY. These procedures should have not been included in the VY emergency plan and removal is an editorial change. New procedure EPOP-URI-1 0095, Offshe Dose Assessment using the Unified Rascal Interface, was added to the Emergency Plan to address the URI change.Reference to these documents is administrative in nature and no further evaluation is required.Renumbering OP 3507 to EPOP-EREC-3507, OP 3508 to EPOP-MED-3508, OP 3510 to EPOP-OSMT-3510, OP 3513 to EPOP-RAD-3513, OP 3547 to EPOP-SEC-3547.

OP 3548 to EPOP-TERM-3548.

AP EN-EP-305 REV 3 ATTACHMENT 9.1 1 0CFR60.54(q)

SCREENING ATICMNT91IIIII05(a SRENN Procedure/Document Number: Emergency Plan -_ Revision:

55 Page 7 of 10 Equipment/Facililty/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan 3712 to EPAP-TRNG-3712 does not impact any of the 10 CFR 50.47(b) planning standard functions or program elements listed In Part V of this form. The changes are administrative in nature and no further evaluation Is required.Non-Editorial Chances Not AffectIna Proaram Elements Associated with an Emernencv Planning Function The following non-editorial changes do not affect program elements associated with an emergency planning function and no further evaluation is necessary.

Section 3.2, Actions In an Emergency, Item 5: The addition of the InForm Notification System as the primary method of performing off-site emergency notifications was evaluated in a 50.54(q) evaluation conducted In December 2013, prior to implementation of Rev. 54 of the Emergency Plan. InForm utilizes source and destination computers that communicate via the Internet to send emergency notifications to the states of Vermont, New Hampshire and Massachusetts during declared emergencies and drills/exercises.

Rev. 54 of the Emergency Plan revised Section 3.2 to state that notification of the three states would be made using the Emergency Notification System rather than the Nuclear Alert System. The Emergency Notification System is used to notify the NRC during an emergency.

This revision changes "Emergency Notification System" to "InForm Notification System" to accurately reflect that notifications to the three states are made using InForm as evaluated In the previous 50.54(q) conducted in December 2013. This revision does not change any facilities or equipment or change any of the processes used to make emergency notifications.

The change does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

Section 5.1, Notfifcation of Unusual Event: This section of the Emergency Plan was revised to remove the reference to changes In operational status when a Notification of Unusual Event is declared.

On September 23,2013, ENO informed the NRC that VY will permanently cease operations at the end of the current operating cycle, which Is expected to occur in the fourth quarter of 2014. 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)(0i)).

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. Because VY will no longer be authorized to operate the reactor or place fuel within the reactor vessel, changes in operational status are no longer possible and references to operational status can be removed from the Emergency Plan. This revision does not change any facilities or equipment or change any of the processes described In the Emergency Plan. The change does not affect program elements associated with the emergency planning functions and no further evaluation Is necessary.

Section 7.3, Utility Microwave and Radio System: This section of the Emergency Plan was revised to remove the discussion of notifying load dispatchers of emergency conditions at the plant. According to Section 10.18.3 of the UFSAR, Rev. 26, the microwave system provides for the Interchange of Information on electrical generation and transmission between the station and the electrical dispatcher.

This system allows the transfer of yard switching information, power level monitoring information and voice contact between the station main control and the electrical system dispatching offices. 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. Because VY will no longer be authorized to operate the reactor or place fuel within the reactor vessel, potential disruptions to the electrical grid due to an emergency condition at VY are no longer possible.

As a result, the need to contact load dispatchers in the event of an emergency at VY no longer exists. The Microwave System will remain in place and serve as a backup means to provide updates of plant conditions to NRC Region I If the commercial telephone system fails. This revision does not change any facilities or equipment or change any of the processes described in the Emergency Plan. The change does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

Table 7.1. Vermont Yankee Emeraencv Communications Matrix: The addition of the InForm Notification EN-EP-305 REV 3 ATTACHMENT 9.1 10CFR50.54(q)

SCREEMNO SProcedure/Document Number: Emergency Plan Revision:

55 Page 8 of 10 Equipment/Facillty/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan System as the primary method of performing off-site emergency notifications was evaluated in a 50.54(q)evaluation conducted in December 2013, prior to implementation of Rev. 54 of the Emergency Plan. InForm utilizes source and destination computers that communicate via the internet to send emergency notifications to the states of Vermont, New Hampshire and Massachusetts during declared emergencies and drilis/exercises.

The Emergency Notification System is used to notify the NRC during an emergency.

This revision adds InForm as "11" in Table 7.1 to accurately reflect that communications with the three states include using InForm as evaluated in the previous 50.54(q) conducted in December 2013. This revision does not change any facilities or equipment or change any of the processes used to make emergency notifications.

The change is administrative in nature, does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

References to Control Room Supervisor (CRS), Control Room Operator (CRO), and Auxiliary Operators (AO): Throughout the Emergency Plan, references to Control Room Supervisor (CRS), Control Room Operator (CRO) and Auxiliary Operators (AOs) have been replaced with Certified Fuel Handler (CFH)and Non-Certified Operators (NCOs). Specifically, changes have been made to Section 8.1, Table 8.4, and Figures 6.3 and 8.1. Emergency Plan changes submitted In BVY 14-018 stated, "Title changes for the CRS and CRO/AO to CFH and NCO, respectively, are dependent upon NRC approval of proposed changes to the VY Technical Specifications (BVY 13-096) that revise the minimum shift staffing requirements in the VY Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs. The Emergency Plan submitted in BVY 14-018 addressed the pending title changes by referring to titles as "CRS/CFH" and AO/CROINCO" and included Note i**" In Table 8.4 Indicating title changes were dependent on NRC approval of BVY 13-096. This Technical Specification change was approved by the NRC by letter dated December 22, 2014 (ML1 4217A072).

The elim ination of CRS, CRO and AO titles and replacement with CFH and NCO Is editorial in nature and no further evaluation is required with respect to this change.Figure 10.1, Vermont Yankee Emergency Dose Rate Nomogram:

Figure 10.1 was deleted. 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. Figure 10.1 is based on the isotopic mix for a LOCA. Because VY will no longer be authorized to operate the reactor or place fuel within the reactor vessel, a LOCA is no longer possible.

This revision does not change any facilities or equipment or change any of the processes described in the Emergency Plan. The change does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

Section 11.3, Public Information:

This section was revised to replace, "routine operating information.

changes in plant operation," with "routine plant information, changes in plant conditions,".

Upon docketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(1))

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. Because VY will no longer be authorized to operate the reactor or place fuel within the reactor vessel, providing "operating information or changes in plant operation Is not possible.

This revision does not change any facilities or equipment or change any of the processes described in the Emergency Plan. The change does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

Appendix C, Initial Offaite Dose Rate Estimation:

Appendix C was deleted. 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. Appendix C is based on the isotopic mix for a LOCA. Because VY will no longer be authorized to operate the reactor or place fuel within the reactor vessel, a LOCA is no longer possible.

This revision does not chance any facilities or eauilpment or chanae anv of the arocesses described in the Emeraencv Plan.EN-EP-305 REV 3 AI~rAcHMENT 9.1 IOCFRSO.54(q)

SCREENING Procedure/Document Number. Emergency Plan Revision:

55 Page 9 of 10 EqulpmentIFeclllty/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan The change does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

Section 8.2, Emergency Response Organization:

This section was revised to delete the bullet, "Plant trip." 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. Because VY will no longer be authorized to operate the reactor or place fuel within the reactor vessel, a plant trip is no longer possible.

This revision does not change any facilities or equipment or change any of the processes described in the Emergency Plan. The change does not affect program elements associated with the emergency planning functions and no further evaluation is necessary.

Section 10.6, Protective Actions for Onalst Personnel:

This section was revised to replace, "safely shut down the reactor" with "maintain equipment Important to safe storage of spent fuel." 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)(11)), 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. Because shutting down the reactor is no longer necessary and the focus Is on maintaining SFP cooling. This revision does not change any facilities or equipment or change any of the processes described in the Emergency Plan. The change does not affect program elements associated with the emergency planning functions and no further evaluation Is necessary.

Non-Editorial Chanage Affecting Proaram Elements Associated with an Emermencv Plannlna Funtlion The remaining changes to Section 7.10 (Emergency Response Data System), Section 10.5.1 (Medical Treatment), Section 10.1.1 (Initial Offslte Radiological Dose Projection Capability), Section 10.1.2 (Variable Trajectory Atmospheric DlspersionlDose Projection Capability), Section 12.1.4 (Medical Drill) and Appendix G (EN-EP-31

1) affect Emergency Planning Standards 10 CFR 50.47(b)(1), (2), (6), (4), (9). (10), (12), (14)and (15) and planning elements 1, 2, 3, 7, 11, 17, 18, 22, 24 and 27 in Part V of this form. These changes are associated with the elimination of the reference to the Medical Response Team and replacement of the existing Offsite Dose Projection System (ODPS) and METPAC dose assessment software with the Unified Rascal Interface (URI). URI will become the primary site specific dose assessment software for Vermont Yankee. A 10 CFR 50.54(q) Evaluation will be performed to determine whether the changes result in a reduction in effectiveness of the Emergency Plan requiring prior NRC approval.A separate 50.54(q) evaluation will be performed to determine whether the retirement of ERDS results in a reduction in effectiveness of the Emergency Plan requiring prior NRC approval.

If the 50.54(q) analysis determines the elimination of ERDS is not a reduction in effectiveness of the VY Emergency Plan, the subsequent elimination of EN-EP-311 Is administrative in nature and no further evaluation is necessary.

EN-EP-305 REV 3 AIrrACHMENT 9.1 IOCFR50.54(q)

SCREENING Procedure/Document Number:. Emergency Plan Revision:

55 Page 10 of 10 EquipmentiFacility/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan Part VI. Signatures:

Preparer Name (Print) Preparer Signature Date: David L Daigle 4<011/27/2015 (Optional)

Reviewer Name (Print) Reviewer Signature Date: Reviewer Name (Print) Reviewer Signature Date: Tom Sowdon .,,'Tom Swdon1-27-2015 Nuclear EP Project Manager ..,vr.Approver Name (Print) Approver Signature Date Mike McKenney EP manager or designee //Z7/513 EN-EP-305 REV 3 ATTACHMENT 9.2 1 OCFR5O.54(q)

EVALUATION ATTACHMENT 9.2 10CFRS0.54(q)

EVALUATION SHEET 1 OF 8 Procedure/Document Number. Emergency Plan I Revision:

55 Equipment/Facility/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan Part I. Description of Proposed Change: The VY Emergency Plan is being revised to eliminate reference to the Medical Response Team and to replace the existing Offaite Dose Projection System (DOPS) and METPAC dose assessment software with the Unified Rascal Interface (URI). URI will become the primary site specific dose assessment software for Vermont Yankee.This evaluation assesses the following changes to the Vermont Yankee Emergency Plan resulting from the proposed elimination of the Medical Response Team: Section 10.5.1- Medical Treatment Replaced, "Medical Response Team members are trained in accordance with station procedures." with"Medical response Is provided by on-shift Fire Brigade members trained In basic first-aid and Cardiopulmonary resuscitation (CPR).*Section 12.1.4. Medical DrIlls* Replaced, "To evaluate the training of the facility'e.medical response team and offaite medical response..." with"To evaluate the training of the facility's medical response and offslte medical response..." This evaluation assesses the following changes to the Vermont Yankee Emergency Plan resulting from the replacement of ODPS and METPAC with URI: Section 10.1.1. Initial Offsite Radioloalcal Dose Prolection Caoabilltv

• Deleted Section Section 10.1.2. Variable Tralectorv Atmospherio Dlsoerslon" Removed, 'Once the EOF/RC Is activated," In the first sentence of first paragraph* Removed "Gaussian," In the second sentence of first paragraph" Removed, "the same" In first sentence of second paragraph" Removed, "used by the model described in Section 10.1.1" in first sentence of second paragraph" Deleted third and fourth paragraph Part I1. Description and Review of Licensing Basis Affected by the Proposed Change: Medical Resnonse Team The UFSAR (Rev. 26), Technical Specifications (Rev. 271), Technical Requirements Manual (TRM) (Rev. 53) and OffsIte Dose Calculation Manual (ODCM) (Rev. 35) were reviewed as part of this analysis.

The documents were searched for the following keywords: a Medical and Medical Response Additionally, the Licensing Research System (LRS) and the Emergency Plan (Rev. 53 and Rev. 54) were searched for relevant Information using the same keywords Identified above and no relevant results were found.The following summarizes the findings of the review.UFSAR (Rev, 201 The UFSAR contains no references to medical response or the Medical Response Team.Technical Specifications (Rev. 2711 The TS contain no references to medical response or the Medical Response Team.Technical Reaulrements Manual (Rev. 53)The TRM contains no references to medical response or the Medical Response Team.Offslte Dose Calculation Manual (ODCM) (Rev. 35)The ODCM contains no references to medical response or the Medical Response Team.EN-EP-305 REV 3 ATrACHMENT 9.2 1 OCFR50.54(q)

EVALUATION SHEET 2 OF 8 Procedure/Document Number: Emergency Plan I Revision:

55 EquipmentlFacility/Other:

Vermont Yankee I Title: Vermont Yankee Emergency Plan Emergencv Plan 1Rev. 53 and 541 Section 10.5.1 states that Medical Response Team members are trained In accordance with station procedures.

Section 12.1.4 states that to evaluate the training of the medical response team and offsite medical response (ambulance and hospital), a medical drill Is conducted annually with a simulated contaminated Injured Individual.

Unified Rascal Interface The method used to perform dose assessment is discussed In Section 10 of the Emergency Plan and the Emergency Plan Implementing Procedures.

A detailed comparison between METPACIODPS and URI Is provided In Attachment 1.In accordance with EN-LI-1 10, the licensing management system used for tracking NRC commitments was searched for items relating to the keywords METPAC, ODPS, and dose assessment.

BVY 13-059, "Commitment for Implementation of Multi-source Dose Assessment Capablityw, was found. URI meets this commitment by providing an automated method for performing a multi-source dose consequences analysis.Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulatlon(s) and Previous Commitment(s)

Made to the NRC: Previous Commitments to the NRC -Per EN-U-1 10, the licensing management system used for tracking NRC commitments (LRS) was searched as described In Part 1i and the results are described in Part II, above.Applicable Regulations:

Medical Response Teem 10 CFR 5$47(bX1)

-Assignment of Responallblify/Organizational Control: Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established and each principal response organization has staff to respond and to augment Its initial response on a continuous basis.10 CFR 50.47(bX2)

-Onaite Emergency Organization:

On-shift facility licenses responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response In key functional areas is maintained at all times, timely augmentation of response capabilities Is available and the Interfaces among various onsite response activities and offsite support and response activities are specified.

10 CFR Part 504 Appendix E Section IVWA -Organization:

The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilties, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

Specifically, the following shall be included: 1. A description of the normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of a. Authorities, responsibilities, and duties of the Individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be In charge of the exchange of Information with offsete authorities responsible for coordinating and Implementing offsite emergency measures.3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities.5. Identification, by position and function to be performed, of other employees of the licenses with special qualifications for coping with emergency conditions that may arise. Other persons with special qualifications, such as consultantsA who are not employees of the licensee and who may be called upon for assistance for emergencies shall also be identified.

The special qualifications of these persons shall be described.

EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EVALUATiON SHEET 3 OF 8 Procedure/Document Number. Emergency Plan I Revision:

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Vermont Yankee Title: Vermont Yankee Emergency Plan 6. A description of the local oftfste services to be provided in support of the licensee's emergency organization.

7. By June 2, 2014, Identification oa, and a description of the assistance expected from, appropriate State, local, and Federal agencies with responsibilities for coping with emergencies.

Including hostile action at the site. For purposes of this appendix, 'hostile action Is defined as an act directed toward a nuclear power plant 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.8. Identification of the State and/or local officials responsible for planning for, ordering, and controllng appropriate protective actions, including evacuations when necessary.

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan Implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified In the emergency plan.10 CFR 50L47(b)(12)

-Emergency Medical Support: Arrangements are made for medical services for contaminated Injured IndMduals.

10 CFR 50.47(bX14)

-Drill and Exercises:

Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

10 CFR 50.47(bX15)

-Emergency Responder Training:

Radiological emergency response training is provided to those who may be called on to assist In an emergency.

10 CFR Part 50, Appendix E Section IV.E (5-7) -Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment, including:

5. Arrangements for medical service providers qualified to handle radiological emergencies onsite;6. Arrangements for transportation of contaminated injured Individuals from the site to specifically Identified treatment facilities outside the site boundary;7. Arrangements for treatment of Individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary;10 CFR Part 50, Appendix E Suction IV.F (1-2) -Training: 1. The program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are fanillar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed In the event of a radiological emergency shall be described.

This shall Include a description of specialized Initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel:

vi. Arat AId and rescue teams vii. Medical support personnel 2. The plan shall describe provisions for the conduct of emergency preparedness exercises as follows: Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public alert and notification system, and ensure that emergency organization personnel are familiar with their duties.Site Compliance:

a licensee organizational description, staffing levels and assignment of responsibilities required by 10 CFR 50.47(b)(1) and (2) and Section IV.A of Appendix E are delineated In Section 8.0 of the VY Emergency Plan, Table 8.4, "Minimum Staffing Requirements for the ENVY ERO." and VY Technical Specification Section 6.0. The Emergency Response Organization (ERO) Is described In Section 8.2 of the VY Emergency Plan. In Table 8.4, first aid responsibilities are assigned to the Fire Brigade. The VY On-Shift Staffing Analysis Report, Rev. 1 (December 19, 2013)and the VY Analysis of Proposed Post-Shutdown On-Shift Staffing submitted to the NRC in Proposed Changes to the Vermont Yankee Emergency Plan (BVY 14-018). developed In accordance with NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" (NEI 10-05), do not consider the Medical Response Team In the analyses because the Medical Response Team is not onsite on a 24-hour per day basis. In accordance with NEI EN-EP-305 REV 3 ATTACHMENT 9.2 1 OCFR50.54(q)

EVALUATION SHEET 4 OF 8 Procedure/Document Number: Emergency Plan Revision:

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Vermont Yankee Title: Vermont Yankee Emergency Plan I. q 10-05 section 2.6. the analyses included a review of rescue operations and first aid response, although neither task was required during the evaluated scenarios.

Additionally, the analyses state that the station fire brigade staff Is trained In first aid and rescue operations and is available to perform these tasks It required, on a 24-hour per day basis. First aid and rescue operations are acceptable collateral duties per the guidance provided In NEI 10-05.Medical support for contaminated Individuals, as required by 10 CFR 50.47(b)(1

2) and Section IV.E of Appendix E Is delineated In Section 10.5 of the VY Emergency Plan.Training for first aid and medical response, required by 10 CFR 50.47(b)(15) and Section IV.F of Appendix E, Is delineated in Sections 10.5 and 12.1.4. Section 10.5.1 states that Medical Response Team members are trained in accordance with station procedures.

Section 10.5.2 addresses arrangements to transport contaminated Injured Individuals offsite for treatment.

Section 12.1.4 states that to evaluate the training of the medical response team and offsite medical response (ambulance and hospital), a medical drill is conducted annually with a simulated contaminated injured Individual.

The emergency plan and Its implementing procedures will continue to assign responsibilities for medical response.

With respect to training lor medical support personnel, the requirement for medical response personnel to successfully complete an EMT Course exceeds the guidance contained in NUREG.0654-FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0854)." This level of training represents a self-Imposed commitment that exceeds regulatory standards and requirements.

Because the training provided for medical response personnel will continue to meet or exceed the Red Cross Multi-Media training Identified in NUREG.0654 Planning Standard 0, Evaluation Criteria 3, the proposed changes to eliminate the requirement for medical response personnel to complete an EMT course and the subsequent changes to Sections 10.5.1 and 12.1.4 of the VY Emergency Pian continue to comply with the VY Emergency Plan, Technical Specifications and applicable regulations.

Unified Rascal Interface 10 CFR 50.47(b)(4)

-Emergency Classification System: 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.Site Comoliance:

URI, like METPAC/ODPS, is a dose assessment tool which can be used to determine if any Emergency Action Levels (EALs) have been reached or exceeded.

The two Vermont Yankee EALs that are tied to dose assessment are AG1.2 and AS1.2. The EAL thresholds are based on exceeding the EPA PAGe or 10% of the EPA PAGs, respectively, at or beyond the site boundary.

The EALs do not delineate the method for determining the calculated dose to the public. URI is an acceptable means of calculating off-site dose due to a radioactive release because it estimates the plume's isotopic content and performs the requisite dose calculations for TEDE and CDE thyroid. Implementation of URI will not affect the classification and emergency action level scheme as described in NEI 99-01, Revision 5 and continues to comply with this planning standard.

Attachment 1 provides a more detailed discussion of why this regulatory standard will continue to be met upon Implementation of this change.10 CFR 50.47(bX9)

-Emergency Assessment Capability:

Adequate methods, systems, and equipment for assessing and monitoring actual or potential offisite consequences of a radiological emergency condition are in use.Site Compliance:

A Radiological Assessment Coordinator with a Health Physics and effluents background performed representative practical exercises on URI and METPAC/ODPS.

The data produced by URI, although not Identical to those of METPAC/ODPS because the URI model is state-of-the-art, showed results and projected plume trajectory that are comparable to that produced by METPACIODPS.

URI Incorporates site-specific terrain, release pathways, process reduction factors, filter efficiencles, monitor response information, meteorological tower features, and other data associated with Vermont Yankee. Therefore, implementation of URI is in compliance with this planning standard.Attachment 1 provides a more detailed discussion of why this regulatory standard will continue to be met upon implementation of this change.10 CFR 50.47(bX10)

-Protective Actions: A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (Kl), as appropriate.

EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR60.84(q)

EVALUATION SHErr 5 oF 8 Procedure/Document Number: Emergency Plan I Revision:

55 EquipmentiFacility/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan I I Evacuation time estimates have been developed by applicants and licensees.

Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and In place, and protective actions for the Ingestion exposure pathway EPZ appropriate to the locale have been developed.

Shie Comnllnce:

In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI) when appropriate.

Evacuation time estimates have been developed and are updated on a periodic basis. Guidelines for the choice of protective actions during an emergency appropriate to the locale and consistent with Federal guidance are In place. Implementation of URI does not affect the mechanism for recommending protective actions to state or local authorities because it does not alter the Protective Action Recommendation process currently used at Vermont Yankee. Therefore, Implementation of URI Is in compliance with this planning standard.

Attachment 1 provides a more detailed discussion of why this regulatory standard will continue to be met upon Implementation of this change.Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change: Medical Response Team 10 CFR 50.47(blt1 I -Asslinment of Resoensibilitv/l0manizational Control" Responsibility for emergency response Is assigned." The response organization has the staff to respond and to augment staff on a continuing basis (i.e., 24/7 support).Sections IV.A.1-iV.A.9 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section I.A of NUREG-0654 and the licensee's emergency plan.10 CFR 50.47(bV21

-Onsite Emnerencv Organizatlon" The process ensures that onshift emergency response responsibilities are staffed and assigned.* The process for timely augmentation of onshift staff Is established and maintained.

Sections IV.A.2.a-c, IV.A.3, and IV.C of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section I.B of NUREG-0654 and the licensee's emergency plan.10 CFR 50.47(bi(121

-Emergencv Medical Suoport* Arrangements are made for medical services for contaminated, Injured individuals.

Sections IV.E.5-7 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section II.L of NUREG-0654 and the licensee's emergency plan.10 CFR 50.47(b(l 41 -Drill and Exercise Proaram" A drill and exercise program (Including radiological, medical, health physics, and other program areas) is established." Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills, are assessed via a formal critique process in order to Identify weaknesses.

• Identified weaknesses are corrected.

Sections IV.F.1-2 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section I.N of NUREG-0654 and the licensee's emergency plan..10 CFR 50.47(b)(1 51 -Emeraencv Responder Training 0 Training is provided to emergency responders.

Sections IV.F.1-2 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear in Section 11.0 of NUREG-0654 and the licensee's emergency plan.EN-EP-305 REV 3 ATrACHMENT 9.2 1 OCFR50.54(q)

EVALUATION SHEET 6 OF 8 Procedure/Document Number: Emergency Plan Revision:

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Vermont Yankee Title: Vermont Yankee Emergency Plan Unified Rascal Interface 10 CFR 50.47(bl(41

-Emeraencv Classification System a A standard scheme of emergency classification and action levels is in use.Sections IV.B and IV.C of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section II.D of NUREG-0654 and the Emergency Plan.10 CFR 50,47ib)(9)

-Emergencv Assessment Caoabllitv

.6 Methods, systems, and equipment for assessment of radioactive releases are In use.Sections IV.B and IV.E.2 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section 11.1 of NUREG-0654 and the Emergency Plan.10 CFR 50.47fb1110)

-Protective Actions* A range of public PARs is available for Implementation during emergencies.

• Evacuation time estimates for the population located In the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.

• A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.Appendix E to 10 CFR 50 does not contain any support requirements.

Informing criteria appear in Section II.J.1-8, Section ]lJ.10, and Supplement 3 of NUREG-0654 as well as the Emergency Plan.Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Medical Reseonse Team Currently, the VY Emergency Plan refers to the Medical Response Team and Indicates it provides onsite medical treatment.

However, the Medical Response Team is not onsite on a 24-hour per day basis and VY's current on-shift staffing analysis and the on-shift staffing analysis for the proposed post-shutdown on-shift staffing proposed in BVY 14-018 do not consider the presence of the Medical Response Team. In VY Emergency Plan Table 8.4, first aid responsibilities are assigned to the Firs Brigade. The proposed changes to Section 10.5.1 and 12.1.4, revise these sections consistent with Table 8.4 and the responsibilities assigned In the VY staffing analyses.Unified Rascal Interface Currently, Section 10.1.1 (Initial Offsite Radiological Dose Projection Capability) of the vY Emergency Plan addresses the initial evaluation of offsite radiological conditions using the ODPS. The revisions to the Emergency Plan will eliminate reference to the ODPS. Section 10.1.2, refers to the 'model described in Section 10.1.1" when describing the model dose projection capabilities.

Section 10.1.2 will eliminate references to Section 10.1.1 while continuing to provide an appropriate description of dose assessment capabilities.

Regulatory Guide 1.219, "Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors provides guidance for determining reductions in effectiveness.

Section 1.8 states: The 10 CFR 50.54(q) change process establishes a two-factor test to determine when a change to an emergency plan requires prior NRC approval.

Rrst the test assesses whether the emergency plan, as modified, would continue to comply with the planning standards In 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR Part 50. Second, the test assesses whether the proposed change would reduce the effectiveness of the emergency plan. These two tests are separate and distinct.

if the licensee does not meet either test, it must obtain prior NRC approval.

Meeting the first EN-EP-305 REV 3 ArrACHMENT 9.2 1 OCFRSO.$4(q)

EVALUATION SHEET 7 OF 8 Procedure/Document Number: Emergency Plan { Revlslon:

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Vermont Yankee Title: Vermont Yankee Emergency Plan teat does not Imply that the licensee has met the second test, nor does meeting the second test Imply that the licensee has met the first test.REGULATORY GUIDE 1.219 TEST PART 1: (Does the chanoe comply with reoulatlons?)

Medical Response Team The licensee organizational description, staffing levels and assignment of responsibilities required by 10 CFR 50.47(b)(1) and (2) and Section IV.A of Appendix E are delineated In Section 8.0 of the VY Emergency Plan, Table 8.4,"Minimum Staffing Requirements for the ENVY ERO." and VY Technical Specification Section 6.0. The Emergency Response Organization (ERO) Is described in Section 8.2 of the VY Emergency Plan. In Table 8.4, first aid responsibilities are assigned to the Fire Brigade. The current VY On-Shift Staffing Analysis Report. Rev. 1 (December 19, 2013) and the VY analysis presented In BVY 14-018, developed In accordance with NEI 10-05, do not consider the Medical Response Team In the analyses because the Medical Response Team Is not onsite on a 24-hour per day basis.In accordance with NEI 10-08 section 2.6, the analyses Included a review of rescue operations and first aid response, although neither task was required during the evaluated scenarios.

Additionally, the analyses state that the station fire brigade stall Is trained in first aid and rescue operations and Is available to perform these tasks If required, on a 24-hour per day basis. First aid and rescue operations are acceptable collateral duties per the guidance provided In NEI 10-05.Medical support for contaminated Individuals, as required by 10 CFR 50.47(b)(12) and Section IV.E of Appendix E Is delineated In Section 10.5 of the VY Emergency Plan.Training for first aid and medical response, required by 10 CFR 50.47(b)(15) and Section IV.F of Appendix E, Is delineated In Sections 10.5 and 12.1.4. Section 10.6.1 states that Medical Response Team members are trained In accordance with station procedures.

Section 10.5.2 addresses arrangements to transport contaminated injured Individuals offsite for treatment.

Section 12.1.4 states that to evaluate the training of the medical response team and ofisite medical response (ambulance and hospital), a medical drill Is conducted annually with a simulated contaminated Injured Individual.

The station fire brigade staff is trained in first aid and rescue operations and Is available to perform these tasks if required, on a 24-hour per day basis.Unified Rascal Interface The method used to perform dose assessment Is discussed in Section 10 of the Emergency Plan and the Emergency Plan Implementing Procedures.

A detailed comparison between METPAC/ODPS and URI is provided In Attachment 1.Attachment 1 contains a detailed effectiveness review of this change including a description of the underlying calculation engine from RASCAL, discussion of the differences between the two dose assessment models, assessment of the impact of the changes to the planning standards, and other supporting information.

REGULATORY GUIDE 1.219 TEST PART 2: (is the change a reduction in effectiveness?)

Medical Resmonse Team The emergency plan and its Implementing procedures will continue to assign responsibilities for medical response.

With respect to medical support personnel, VY's use of the Medical Response Team exceeds the guidance contained In NUREG-0654-FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness In Support of Nuclear Power Plants (NUREG-0654)." This level of response represents a sell-imposed commitment that exceeds regulatory standards and requirements.

Because the medical response continues to comply with applicable regulations and training provided for medical response personnel will continue to meet or exceed the Red Cross Multi-Media training Identified In NUREG-0654 Planning Standard 0, Evaluation Criteria 3, the proposed changes to eliminate the Medical Response Team and the subsequent changes to Sections 10.5.1 and 12.1.4 of the VY Emergency Plan continue to comply with the VY Emergency Plan, Technical Specifications and applicable regulations.

Because the Medical Response Team Is not onsite 24-hours per day, VY's current on-shift staffing analysis and the analysis for the proposed post-shutdown on-shift staffing proposed In BVY 14-018 do not consider the presence of the Medical Response Team, and VY Emergency Plan Table 5.4 assigns first aid responsibilities to the Fire Brigade, the proposed change to eliminate the Medical Response Team continues to comply with the applicable requirements contained In 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. This change continues to align with the requirements of Appendix E to 10 CFR Part 50 and does not represent a reduction in the effectiveness of the Emergency Plan and can be implemented without prior NRC approval.EN-EP-305 REV 3 ATTACHMENT

9.2 SHEET

8 OF 8 1 OCFR5O.54(q)

EVALUATION Procedure/Document Number: Emergency Plan I RevliIon:

55 Equipment/Facility/Other:

Vermont Yankee Title: Vermont Yankee Emergency Plan Unified Rascal Interface The impact of the proposed changes will be to improve the ability of Vermont Yankee to protect the health and safety of the public by providing an improved process to calculate estimates of offsite airborne concentrations and dose rates Including those resulting from multiple release points. Attachment I contains a detailed effectiveness review of this change including a description of the underlying calculation engine from RASCAL, discussion of the differences between the two dose assessment models, assessment of the impact of the changes to the planning standards, and other supporting information.

Adopting URI as the primary dose assessment software continues to comply with the planning standards outlined in 10 CFR 50.47 (b) 4,9. and 10. Replacing METPAC/ODPS with URI is not a reduction In the effectiveness of the Emergency Plan and can be incorporated without prior NRC approval.Part VI. Evaluation Conclusion Answer the following questions about the proposed change.1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? OYES [0 NO 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no OYES 3 NO reduction in effectiveness)?

aYES -NO 3. Does the proposed change constitute an emergency action level scheme change?_ [OYES [] NO If questions I or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50.90. If questions I and 2 are answered YES, and quesion 3 answered NO, Implement applicable change process(es).

Refer to step 5.6[8].Part VII. Signatures Preparer Name (Print) Preparer Signature Date: David L. Dalgle g 01/2612015 (Optional)

Reviewer Name (Print) Reviewer Signature Date: Reviewer Name (Print) Reviewer Signature Date: Tom Sowdon 1-2-2015 Nuclear EP Project Manager 2015 Approver Name (Print) Approver Signature Date: MP McKenney EP Manager or designeeZ1 , 5 EN-EP-305 REV 3 Attachment 1

of the URIURASCAL Underlying Implementation The Unified RASCAL Interface (URI) computer program Is a new dose assessment program based on the calculation engine of the NRC code RASCAL. This dose assessment program will replace the site-specific dose assessment codes currently in use at Vermont Yankee. This 50.54(q) evaluation will evaluate the following attributes of URI." The Unified RASCAL Interface (URI) dose assessment computer program* The URI Requirements Specification

• The URI Requirements Specification Annex for Vermont Yankee" The RASCAL Interface Technical Resource Kit" The URI Maintenance Computer Program The reason for the change Is to implement the new atmospheric dispersion models of RASCAL that offer a streamlined user Interface utilizing instrumentation and terminology available at the site. The new dispersion models used in the NRC's RASCAL code have been extensively verified and validated as referenced In Section 4.10 of the RASCAL 4, "Description of Models and Methods", June 2, 2010. The RASCAL dispersion models provide a more accurate depiction of plume dispersion as compared to the Department of Energy MESODIF-Il methodology currently employed by the Meteorological Plant Access Computer (METPAC).

The new dispersion models will ensure a more accurate estimate of the dose to the public when compared to METPAC/ODPS.

URI consists of the following dose assessment methodologies.

Rapid Assessment:

Can be used by the on-shift dose assessor to perform dose assessments with minimal information available.

Rapid Assessment includes assessment methodologies using effluent monitors, containment high range area monitors and pre-determined fuel damage estimates.

The decision for on-shift personnel to use the rapid assessment instead of the detail assessment has not been made at this time.Detailed Assessment:

is used by the augmented emergency response staff in the TSC or EOF where a much greater degree of source term and plant status Information will be available to perform more refined assessments.

Detailed Assessment includes assessment methodologies using effluent monitors, containment high range area monitors, fuel damage estimates, effluent sample results, and field team results.URI consists of a front and back end interface to the NRC's RASCAL computer code. In its simplest form the URI code operates as follows.1. Based on user Input the program calculates a release rate for a given set of isotopes and produces a file formatted to meet the RASCAL input requirements.

2. Based on user input the program creates a meteorological data file formatted to meet the RASCAL input requirements.

3. The RASCAL meteorological processor is invoked.4. The RASCAL dose processors are invoked producing files containing results that Include" Exposure Rates* Doses due to External Shine, Inhalation, and Deposition" Airborne Iodine Concentrations" TEDE and CDE Thyroid Dose 5. The URI program reads the RASCAL output files containing the calculated data and displays the data in standard reports and forms.Page 1 of 10 Attachment I Details related to the actual process are delineated In the URI Requirements Specification document.Because the Individual URI site compUter programs utilize an external encrypted xml format data file, an additional computer program referred to as the maintenance program exists. This program Is used to maintain pertinent information within a database related to the site and to generate the encrypted file when changes to the underlying data are made. This program only creates a data file used by the URI programs; it does not actually perform dose assessment functions.

Proaram Reauirements 50.47(bX4)

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 01 mInimum initial offsete response measures.NUREG-0654 II.D 1. An emergency classification and emergency action level scheme as set forth In Appendix I must be established by the licensee.

The specific instruments, parameters, or equipment status shall be shown for establishing each emergency class In the in-plant emergency procedures.

The plan shall Identify the parameter values and equipment status for each emergency class.50.47(b)(9)

Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.NUREG-0654 11.1 1. Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall Identify the plant parameter values or other information which correspond to the example Initiating conditions of Appendix 1. Such parameter values and the corresponding emergency class shall be included in the appropriate facility emergency procedures.

Facility emergency procedures shall specify the kinds of Instruments being used and their capabilities.

2. Onsite capability and resources to provide Initial values and continuing assessment throughout the course of an accident shall include post-accident sampling capability, radiation and effluent monitors, in-plant iodine Instrumentation, and containment radiation monitoring in accordance with NUREG-0578, as elaborated in the NRC letter to all power reactor licensees dated October 30, 1979.3. Each licensee shall establish methods and techniques to be used for determining:

a. the source term of releases of radioactive material within plant systems. An example Is the relationship between the containment radiation monitor(s) reading(s) and radioactive material available for release from containment.

b. the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors.4. Each licensee shall establish the relationship between effluent monitor readings and onsite and offsite exposures and contamination for various meteorological conditions.

5. Each licensee shall have the capability of acquiring and evaluating meteorological information sufficient to meet the criteria of Appendix 2. There shall be provisions for access to meteorological information by at least the near-site Emergency Operations Facility, the Technical Support Center, the Control Room, and an offsite NRC center. The licensee shall make available to the State suitable meteorological data processing Interconnections which will permit independent analysis by the State, of facility generated data In those States with the resources to effectively use this information.

Page 2 of 10 Attachment I 6. Each licensee shall establish the methodology for determining the release rate/projected doses if the instrumentation used for assessment Is offscale or Inoperable.

7. Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways.

This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.9. Each organization shall have a capability to detect and measure radiolodine concentrations In air in the plume exposure EPZ as low as 107 pci/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity.10. Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given In Table 3, page 18) and gross radioactivity measurements.

Provisions shall be made for estimating Integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action guides. The detailed provisions shall be described In separate procedures.

50.47(b)(10)

A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate.

Evacuation time estimates have been developed by applicants and licensees.

Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the Ingestion exposure pathway EPZ appropriate to the locale have been developed.

NUREG-0854 II.J 7. Each licensee shall establish a mechanism for recommending protective actions to the appropriate State and local authorities.

These shall Include Emergency Action Levels corresponding to projected dose to the population-at-risk, in accordance with Appendix 1 and with the recommendations set forth in Tables 2.1 and 2.2 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-52011-75-001).

As specified in Appendix 1, prompt notification shall be made directly to the offsite authorities responsible for Implementing protective measures within the plume exposure pathway Emergency Planning Zone.Change Comparlson URI represents an improvement over METPAC/ODPS.

The URI dose assessment program retains all of the site specific parameters and inputs that were common to the METPAC/ODPS program. Therefore, there are no changes to site specific parameters and inputs that Impact compliance with the program requirements above. A site specific analysis was performed to validate and verify all release pathways.

Monitors and release paths used for dose projections by METPAC/ODPS continue to be used by URI.The URI dose assessment program uses RASCAL 4.2 to perform all estimates of atmospheric dispersion.

RASCAL 4.2 uses the RATCHET (Regional Atmospheric Transport Code for Hanford Emission Tracking)model which Is based on the MESODIF model employed by METPAC/ODPS.

The RATCHET code Implements a Lagranglan trajectory, Gaussian puff dispersion model. Transport, diffusion, and deposition of material In the puffs are controlled by wind, atmospheric stability, precipitation, and mixing-layer depth fields that describe the spatial and temporal variations of meteorological conditions throughout the domain.Page 3 of 10 Attachment 1 The methodology for calculating diffusion coefficients in RATCHET uses the turbulence parameters sigma v and sigma w. Sigma v is the standard deviation of the fluctuation of the horizontal component of the wind vector perpendicular to the mean wind direction.

Sigma w Is the standard deviation of the vertical component of the wind vector. RATCHET therefore calculates the dispersion parameters as needed based on current atmospheric and surface conditions.

Because of this, the dispersion parameters are a function of time and not distance like the classic Pasquili-Gifford curves.URI uses the RASCAL TADPLUME40.dil and TADPUFF40.dIl computer files to calculate dose. As such, the dose conversion factors have changed when compared to those used In METPACIODPS.

The dose conversion factors used in RASCAL are based primarily on Federal Guidance Report Number 11 and Federal Guidance Report Number 12, "External Exposure to Radionuclides in Air, Water, and Soil". Federal Guidance Report Number 12 is a newer reference than DOE 1988 and therefore has updated dose conversion factors.RASCAL is a sophisticated model that performs calculations for cloud shine dose doing actual integrations over the model domain.The RATCHET Code has been validated in a number of tests. The algorithms used have been extensively reviewed by leading experts in the field Including the National Academy of Sciences.

As documented in section 4.10 of the RASCAL Manual, the reasons the RATCHET algorithms were used in RASCAL is that the RATCHET code has received extensive peer review and validation.

The RATCHET code has also been validated against actual releases.

The Federal Radiological Monitoring and Assessment Center (FRMAC)Assessment Working Group compared RASCAL 4.0 and 4.1 against Turbo FRMAC 2010 and found RASCAL 4.0 and 4.1 to be consistent with Turbo FRMAC 2010.Another study of different dose models was performed in NUREG/CR-6853, "COMPARISON OF AVERAGE TRANSORT AND DISPERSION AMONG A GAUSSIAN, A TWO-DIMENSIONAL AND A THREE-DIMENSIONAL MODEL", October 2004. Some of the codes used for comparison were RATCHET, an older version of RASCAL, and a simplified Gaussian model, MACCS2. In this particular test, each model was run to produce the annual average integrated exposure and deposition for a series of rings from 10 to 100 miles from a hypothetical release. The conclusion from these studies, as referenced in the current RASCAL Manual, shows that RASCAL 4 which uses RATCHET produces lower doses on average than RASCAL 3.0.5.Implementing the RACHET code also significantly improves the modeling of calm (wind speeds less than 1 mph) weather conditions.

URI uses RASCAL's meteorological processor and dose processors.

This incorporates the use of multiple meteorological off-site towers and topographical data. In 1977, the American Meteorological Society Committee on Atmospheric Turbulence and Diffusion estimated the upper limit of accuracy for diffusion models to be about a factor of two under conditions where the meteorological parameters controlling diffusion are measured near the point of release and where topographic relief is minimal., A greater uncertainty approaching a factor of 10 was established for conditions when the wind speed decreases toward calm. As previously stated, implementing calm weather conditions was one of the benefits of Implementing the URI interface to RASCAL which uses the RACHET code.The algorithms and methods used for dispersion and dose calculation are the same as those used in RASCAL and therefore have been evaluated and benchmarked against other methodologies.

Testing has been performed to ensure that the specific URI version produces reasonable results when compared to RASCAL.There are three main reasons for changing Vermont Yankee's dose assessment program from METPAC/ODPS to URI. First, METPAC/ODPS Is a DOS based program which cannot be run in the current Windows environment and Is no longer supported or maintained by the vendor that designed it. Second, METPAC/ODPS's noble gas release mixtures are based on a LOCA I category which uses the mixture expected from the release of primary coolant at equilibrium concentrations with one percent failed fuel and a LOCA III category which uses the mixture expected from some degree of core damage that has resulted In a rapid release of fission products into reactor coolant. These are not applicable to a permanently defueled plant where the spent fuel pool and Independent Spent Fuel Storage casks are the sources of a release to the environment.

Finally, URI is capable of automated multi-source dose assessment while METPAC/ODPS Is not.Page 4 of 10 Attachment 1 Chanae Assessment 50.47(b)(4)

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.NUREG-0654 II.D 1. An emergency classification and emergency action level scheme as set forth In Appendix 1 must be established by the licensee.

The specific Instruments, parameters or equipment status shall be shown for establishing each emergency class, In the In-plant emergency procedures.

The plan shall identify the parameter values and equipment status for each emergency class.Implementation of URI will not affect the classification and emergency action level scheme as described In NEI-99-01.

URI, like METPACIODPS, is a dose assessment model used as a tool to determine if an emergency classification has been exceeded.

Vermont Yankee has two EALs that are tied to dose assessment.

The thresholds for EALs AG1.2 and AS1.2 are based on exceeding the EPA PAGs or 10%of the EPA PAGs for TEDE or thyroid CDE, respectively, at or beyond the site boundary.

The EALs do not delineate the method for determining the calculated dose to the public. URI Is an acceptable means of calculating off-site dose due to a radioactive release because it estimates the plume's isotopic content and performs the requisite dose calculations for TEDE and thyroid CDE.Implementation of URI does not affect the EAL scheme or thresholds and continues to comply with this planning standard.50.47(bX9)

Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.NUREG-0654 11.1 1. Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall Identify the plant parameter values or other Information which correspond to the example Initiating conditions of Appendix 1.Such parameter values and the corresponding emergency class shall be Included In the appropriate facility emergency procedures.

Facility emergency procedures shall specify the kinds of Instruments being used and their capabilities.

URI is structured so that all pertinent effluent monitors and radiation monitors that may provide an early indication of off normal conditions are available as inputs to perform dose assessment.

URI provides methods to limit the entered value for each monitor used in an assessment along with other limiting functions such as not allowing assessments to be performed using non-pertinent data points or information.

Implementation of URI/RASCAL supports spent fuel as well as ISFSI accidents and continues to comply with this planning standard.2. Onslte capability and resources to provide Initial values and continuing assessment throughout the course of an accident shall Include post-accident sampling capability, mdlatlon and effluent monitors, In-plant Iodine Instrumentation, and containment radiation monitodng In accordance with NUREG-0578, as elaborated in the NRC letter to all power reactor licensees dated October 30, 1979.URI is structured so that all spent fuel and ISFSI accident instrumentation Is available for input into the dose assessment model. Implementation of URIJRASCAL continues to comply with this planning standard.Page 5 of 10 Attachment I 3. Each licensee shall establish methods and techniques to be used for determining:

a. the source term of releases of radioactive material within plant systems. An example is the relationship between the containment radiation monitor(s) reading(s) and radioactive material available for release from containment.

Spent Fuel Accident In the case of a spent fuel accident, source terms are available for the fuel being underwater, partially uncovered, or dry. If the fuel Is underwater, the fuel Is assumed to be cooled and the only damage to would be to the cladding.

Percentage of damage Is limited to the design basis accident event described in Vermont Yankee's UFSAR. This value is described in detail in the Vermont Yankee URI Site Annex.If the fuel is partially uncovered or dry, it Is assumed that the zircalloy cladding has ignited and 100% of the fuel from a standard core Is Involved in this type of accident.

The source term Is adjusted accordingly based on the 100% MWth power using the uCiIMWth values described in the Reactor Core Accident section of the Vermont Yankee URI Site Annex.Available release activities for each isotope are adjusted by spent fuel release fractions associated with the status of the fuel (under water or exposed to air). Release fractions for spent fuel were obtained from Table 2.1 of the RASCAL 4: Description of Models and Methods document and Table 3.2 of NUREG/CR-6451.Release Point Sample-Analysis Results An additional source term is available based on a user entered release rate or concentration for each of the 33 isotopes of Interest.

These values are obtained based on actual samples at the release point to the environment.

Since the actual values cannot be pre-determined, the user Is required to enter these values manually.

Doing so over-rides any assumed mixtures based on pre-determined values. Any values not entered are assumed to be 0.Field Team Survey Results Values for collection and counting efficiency of the Instruments used at Vermont Yankee are incorporated Into the calculation.

A conversion factor derived by dividing the EPA-400 CDE thyroid factor of 1.3 E+06 by the EPA-400 breathing rate of 1.2 E+06 is then applied to the field monitoring team data to perform the dose assessment.

Implementation of URVRASCAL uses a source term that supports spent fuel as well as ISFSI accidents which continues to comply with this planning standard.3. Each licensee shall establish methods and techniques to be used for determining:

b. the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors.URI has the capability to utilize data from installed effluent monitors or portable Instrumentation to determine the magnitude of a release. Monitor readings are converted to release rates for each Isotope based on a predetermined monitor conversion factor. Conversion factors are based on the Isotopes used for each monitor's calibration.

Monitor responses can be further adjusted based on isotopic correction factors or time dependent correction factors due to expected changes In effluent isotopic mixture ratios resulting from radioactive decay.Page 6 of 10 Attachment I URI also applies factors which reduce the particulate and Iodine release rates due to mechanical processes such as hold-up times and ventilation filtration.

These functions are related to the pathway that the effluent takes from Its source to the environment.

These mechanical processes can have a significant effect on the total activity released to the environment.

All the reduction factors are assumed to operate on all radionuclides except noble gases. None of the reduction factors reduce the activity of the noble gas release to the environment.

All nuclides subject to a given reduction mechanism are assumed to have the same reduction factor. Radioiodines are treated the same as all other non-noble gas nuclides.

These are the same assumptions described in Section 1.4 of the RASCAL 4: Description of Models and Methods document.URI uses the NUREG-1228 pathways as a starting point. URI expands on these to make it easier to identify the pathway of interest without having to Interpret mechanical processes that might or might not be applicable to the actual pathway the effluent is taking to the environment.

The number of decisions needed to apply mechanical process has been streamlined to only those applicable to the actual conditions.

Implementation of URI/RASCAL allows for adjustment of the magnitude of a release based on system parameters which is considered an enhancement to the dose assessment process. Its use continues to comply with this planning standard.4. Each licensee shall establish the relationship between effluent monitor readings and onsite and offsite exposures and contamination for various meteorological conditions.

URI provides methodologies for calculating release rates using release point effluent monitors.

The Monitored Release methodology uses conversion factors for each release point to determine an equivalent gross concentration or release rate depending on how the data Is delivered from the Plant Data System. URI can do additional calculations using Individual isotopic conversion factors or time dependent conversion factors. These are described in detail in the Requirements Specification and Vermont Yankee URI Site Annex. When a calculation is performed, a release rate Is calculated and processed using the RASCAL dose processors.

URI uses predetermined onsite meteorological tower data and optional meteorological data from offsite sources. Required Input fields are wind speed, wind direction, stability class, and precipitation.

When a calculation Is performed, all entered meteorological data is processed in RASCAL using the meteorological processor.

Implementation of URI/RASCAL establishes a relationship between effluent monitor readings and offsite exposures and contamination for entered metrological conditions which continues to comply with this planning standard.5. Each licensee shall have the capability of acquiring and evaluating meteorological Information sufficient to meet the criteria of Appendix 2. There shall be provisions for access to meteorological Information by at least the near-site Emergency Operations Facility, the Technical Support Center, the Control Room and an offolte NRC center. The licensee shall make available to the State suitable meteorological data processing Interconnections which will permit independent analysis by the State, of facility generated data in those States with the resources to effectively use this Information.

URI does not require additional meteorological data beyond what is required for METPAC/ODPS.

URI does have additional capabilities beyond that of METPAC/ODPS in that it can utilize multiple meteorological towers for dose assessment.

Implementing URI will have no effect on available meteorological towers and their associated information at a Vermont Yankee emergency facility or at a state or federal facility.

Provision for data processing interconnections associated with the site meteorological monitoring program remains unchanged.

Implementation of URI/RASCAL continues to comply with this planning standard.Page 7 of 10 Attachment 1 6. Each licenase shall establish the methodology for determining the release rate/projected doses if the Instrumentation used for assessment Is offecale or Inoperable.

Normally, assessments are performed using installed or portable effluent monitors.

However, when they are not available or not part of the release pathway, URI provides alternative methods to calculate a release rate. Subsequent projected doses are based on the calculated release rate using the RASCAL meteorological and dose processors.

A unique dose calculation model Is not required for each alternate method to determine a calculated dose.Release Point Sample Result concentrations for the 33 isotopes of interest can be entered directly into the program to determine a release rate based on a given release point flow rate. Any isotope concentrations not entered are assumed to be 0.Field Team Results can be utilized to back calculate a source term and subsequent doses by rationing a predetermined release to actual field team results. Field team environmental data with input fields for exposure rate and iodine concentration are used to calculate a release rate ratio. URI results are then adjusted by this ratio before being displayed to the end user.Implementation of URI/RASCAL continues to comply with this planning standard.7. Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an Intrinsic part of the concept of operations for the facility.Implementation of URI/RASCAL does not affect field monitoring activities and continues to comply with this planning standard.

However, field monitoring team results can be used to calculate projected doses as described in 6 above.8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways.

This shall Include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.Implementation of URI/RASCAL will not affect activation, notification, field team composition, transportation, communication, or monitoring equipment at Vermont Yankee and continues to comply with this planning standard.9. Each organization shall have a capability to detect and measure radiolodine concentrations in air In the plume exposure EPZ as low as 10.' ucilcc (microcurles per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity.URI does not affect the ability of the field teams to collect or count air samples in the field. Minimum detectable activities are determined based on sample collection efficiency, sample volume, and counting equipment efficiency.

URI does provide a method for calculating particulate and Iodine air sample results including a Lower Limit of Detection (LLD) value to help determine the validity of the sample results when used for dose assessment.

Implementation of URI/RASCAL continues to comply with this planning standard.Page 8 of 10 Attachment I 10. Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key Isotopes (i.e., those given In Table 3, page 18) and gross radioactivity measurements.

Provisions shall be made for estimating Integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action guides. The detailed provisions shall be described In separate procedures.

URI provides methodologies to convert airborne activity levels to dose based on calculated gaseous release rates for a given set of isotopes.

These isotopes are defined in NUREG 1228 Table 2.2. These 33 isotopes are based on the WASH-1400 values that contribute to early health effects. All of the isotopes listed In Table 3 are Included In URI. URI contains two options for estimating integrated dose.The user may input the release duration to calculate the integrated dose values, or use results of the current evacuation time estimate for release duration.

In either case, the integrated dose Is compared to the EPA PAG values. Areas where the PAGs are exceeded are highlighted on a graphical display. This method can be used with projected or actual dose rates.Implementation of URI/RASCAL continues to comply with this planning standard.50.47(b)(10)

A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate.

Evacuation time estimates have been developed by applicants and licensees.

Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

NUREG-0654 II.J 7. Each licensee shall establish a mechanism for recommending protective actions to the appropriate State and local authorities.

These shall Include Emergency Action Levels corresponding to projected dose to the population-at-risk, in accordance with Appendix I and with the recommendations set forth in Tables 2.1 and 2.2 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-520/1-75-001).

As specified In Appendix 1, prompt notification shall be made directly to the offslte authorities responsible for implementing protective measures within the plume exposure pathway Emergency Planning Zone.In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI) when appropriate.

Evacuation time estimates have been developed and are updated on a periodic basis. Guidelines for the choice of protective actions during an emergency appropriate to the locale and consistent with Federal guidance are In place. Implementation of URI does not affect the mechanism for recommending protective actions to state or local authorities because it does not alter the Protective Action Recommendation process currently used at Vermont Yankee.Implementation of URI/RASCAL continues to comply with this planning standard.Page 9 of 10 Attachment 1 References RASCAL 4, "Description of Models and Methods", June 2, 2010 Regulatory Guide 1.145, "ATMOSPERIC DISPERSION MODELS FOR POTENTIAL ACCIDENT CONSEQUENCE ASSESSMENTS AT NUCLEAR POWER PLANTS", PAVAN (Bander, T.J. 1982), NUREG/CR-2858 "An Atmospheric Dispersion Program for Evaluating Design Basis Accidental Releases for Radioactive Materials from Nuclear Power Stations" XOQDOQ (Sagendorf, Gol, and Sanddursky 1982.) NUREG/CR 4380, "Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations" MESORAD (Scherpelz et. Al. 1986; Ramsdell et. al 1988), 'The MESORAD Dose Assessment Model", Volume 1, NUREG/CR-4000.

1 OCFR Part 100, "Reactor Site Criteria" RATCHET (Regional Atmospheric Transport Code for Hanford Emission Tracking)"Meteorological and Atomic Energy" 1968 ("D. Slade" TID 24190 US Atomic Energy Agency)NUREG/CR-3332 "RADIOLOGICAL ASSESSMENT, A TEXTBOOK ON ENVIRONMENTAKL DOSE ANALYSIS" EPA-400, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents".

DOE 1988, "External Dose-Rate Conversion Factors for Calculation of Dose to the Public" Federal Guidance Report number 11, "Urmiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion".

Federal Guidance Report Number 12, "External Exposure to Radlonuclides in Air, Water, and Soir.NUREG/CR-6853, "COMPARISON OF AVERAGE TRANSORT AND DISPERSION AMONG A GAUSSIAN, A TWO-DIMENSIONAL AND A THREE-DIMENSIONAL MODEL", October 2004.NEI 01, "Methodology for Development of Emergency Action Levels" Page 10 of 10 ATTACHMENT

9.1 SHEET

1 OF 3 1OCFR50.54(q)

SCREENING Procedure/Document Number: Emergency Plan Revision:

55 EquipmentlFacility/Other:

Vermont Yankee ERDS Title: Vermont Yankee Emergency Plan Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the Implementation of the emergency plan): This screening addresses the retirement of the Emergency Response Data System (ERDS) in the Emergency Plan (Section 7.10), EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," EPAD-0093, "Emergency Planning Data Management," and AP-1 0049, "Equipment Important to Emergency Response' and the removal of Vermont Yankee from EN-EP-31 1," Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)." Part II. Activity Previously Reviewed?

E]YES Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3)

Continue to Alert and Notification System Design Report? Evaluation is next part NOT required.Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and proposed change is documented below: complete Part VI.Justification:

[I Bounding document attached (optional)

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

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

Screening.

APPLICABILITY CONCLUSION 0 If there are no controlling change processes, continue the 50.54(q)(3)

Screening.

EO One or more controlling change processes are selected, however, some portion of the activity Involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3)

Screening for that portion of the activity.

Identify the applicable controlling change processes below.O One or more controlling change processes are selected and fully bounds all aspects of the activity.

50.54(q)(3)

Evaluation is NOT reauired.

Identify controllina chanoe orocesses below and comolete Part VI.CONTROLLING CHANGE PROCESSES 10 CFR 50.54(q)Part IV. Editorial Change D-OYES 10 NO 50.54(q)(3)

Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.Justification-Enter justification and complete Part VI.EN-EP-305 REV 3 ATTACHMENT

9.1 SHEET

2 OF 3 10CFR5O.54(q)

SCREENING Procedure/Document Number: Emergency Plan Revision:

55 EquipmentlFacility/Other:

Vermont Yankee ERDS Title: Vermont Yankee Emergency Plan Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identifled in brackets)

Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section Ii?1. Responsibility for emergency response is assigned.

(1] , 2. The response organization has the staff to respond and to augment staff on a continuing basis (2417 5 staffing) in accordance with the emergency plan. (1]3. The process ensures that on shift emergency response responsibilities are staffed and assigned.

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

[2] )5. Arrangements for requesting and using off site assistance have been made. [31 El 6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [31 El 7. A standard scheme of emergency classification and action levels is in use. [4] 5 8. Procedures for notification of State and local governmental agencies are capable of alerting them of El the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications.

[5]9. Administrative and physical means have been established for alerting and providing prompt 5 instructions to the public within the plume exposure pathway. [5]10. The public ANS meets the design requirements of FEMA-REP-IO, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]11. Systems are established for prompt communication among principal emergency response organizations.

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

[6] El 13. Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). [7]14. Coordinated dissemination of public information during emergencies is established.

(7]15. Adequate facilities are maintained to support emergency response.

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

[8] E]17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] El 18. A range of public PARs Is available for implementation during emergencies.

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

[10]20. A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.[1 0]EN-EP-305 REV 3 ATTACHMENT

9.1 SHEET

3 OF 3 10CFR50.54(q)

SCREENING Procedure/Document Number: Emergency Plan Revision:

55 Equipment/FacilitylOther:

Vermont Yankee ERDS Title: Vermont Yankee Emergency Plan 21. The resources for controlling radiological exposures for emergency workers are established.

[11]22. Arrangements are made for medical services for contaminated, injured individuals.

(121 23. Plans for recovery and reentry are developed.

(13]24. A drill and exercise program (including radiological, medical, health physics and other program 0 areas) is established.

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

(141 26. Identified weaknesses are corrected.

[14]27. Training is provided to emergency responders.

(15] 0 28. Responsibility for emergency plan development and review is established.

[16] El 29. Planners responsible for emergency plan development and maintenance are properly trained. [16) ___...APPLICABILITY CONCLUSION O If no Part V criteria are checked, a 50.54(q)(3)

Evaluation is NOT required; document the basis for conclusion below and complete Part VI.If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3)

Evaluation.

BASIS FOR CONCLUSION Emergency Planning Standard 10 CFR 50.47(b)(6) and planning standard element 11 in Part V of this form are affected by the retirement of ERDS. A 10 CFR 50.54(q) Evaluation will be performed to determine whether the effectiveness of the Emergency Plan is reduced and prior NRC approval is required.Part VI. Signatures:

Preparer Name (Print) Preparer Signature Date: David L. Daigle ..11/25/2014 (Optional)

Reviewer Name (Print) Reviewer S' Date: Reviwerblen~e t) 61e* S aatffDate:

Nuclea -P o'ct a, r..,Date: Ap r r N~aiý Pnnt(P .ý S a re Date: EP ma~a~er'orW Sgne4.. ./Z .Z./A f I EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR5O.54(q)

EVALUATiON SHEET 1 OF 7 Procedure/Document Number: NA Revision:

NA EquipmentiFacilityiOther:

Vermont Yankee ERDS Title: NA Part I. Description of Proposed Change: This evaluation addresses the retirement of the Emergency Response Data System (ERDS) and removal of ERDS from the Emergency Plan (Section 7.10), EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546,"Emergency Operations Facility/Recovery Center (EOF/RC)," EPAD-0093, "Emergency Planning Data Management," and AP-1 0049, "Equipment Important to Emergency Response" and the removal of Vermont Yankee from EN-EP-311

," Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)." Part II. Description and Review of Licensing Basis Affected by the Proposed Change: The Emergency Plan (Rev. 53 and 54), UFSAR (Rev. 26), Technical Specifications (Rev. 271), and Technical Requirements Manual (TRM) (Rev. 53) were searched for the following keywords:

Emergency Response Data System and ERDS. Additionally, EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," EPAD-0093, "Emergency Planning Data Management," and AP-1 0049,"Equipment Important to Emergency Response" were searched for the following keywords:

Emergency Response Data System and ERDS. EN-EP-31 1," Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)" was searched for Vermont Yankee and VY.ERDS is not identified in Technical Specifications or the Technical Requirements Manual.Per EN-LI-1 10, the licensing management system used for tracking NRC commitments (LRS) was searched for references to ERDS and no results were found.ERDS was Identified In the following:

Emeraency Plan According to Section 7.10 of the VY Emergency Plan, "ERDS is a direct real-time electronic transmission of the following types of data to the NRC to assist them in monitoring the status of an emergency:

1) core and coolant system data, 2)containment building data, 3) radioactivity release data, and 4) site meteorological data. Vermont Yankee maintains a continuous ERDS connection with the NRC Operations Center." UFSAR Section 7.15.1 of the UFSAR (Rev. 26) states that the Process Computer System (PCS) exports data to an Emergency Response Data System (ERDS) function and that, once activated, ERDS sends selected current plant data points to the NRC Operations Center on a periodic basis. Section 7.15.2, Item #4 states that the PCS data export feature shall support the following ERDS functions (resident on another system): Capable of being manually activated within one hour; Once activated, will establish data communications with the NRC ERDS computer system,; Transmit critical plant data in the proper format and protocol at time intervals of not less than 15 seconds or more than 60 seconds, until the link is manually disconnected, and; If the data connection is lost, the ERDS interface module Is responsible for re-establishing communication with the ERDS computer.EPOP-TSC-3542 Step 1.2 of Attachment 2 of EPOP-TSC-3542 states that the TSC Manager Is responsible for ensuring the IT Specialist has verified the ERDS connection.

Step 1.2 of Attachment 12 instructs the IT Specialist to verify the ERDS connection per EN-EP-31 1. Step 1.2 of Attachments 2 and 12 of EPOP-TSC-3542 both contain the following list of Notes:* Vermont Yankee maintains a continuous connection to the NRC using the Emergency Response Data System (ERDS)* Per 1 OCFR50.72 (a)(4) ERDS must be activated as soon as possible, but not later than one hour, after the initial declaration of an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY." Initial verification of the ERDS connection with the NRC will be performed by the IT Specialist.

If the IT Specialist is unable to verify the connection within the required time, then one of the following (in this order) will perform the verification:

EOF Off-site Communicator, EP Department Personnel.

Step 3.1 of Attachment 12 of EPOP-TSC-3542 instructs the IT Specialist to not disconnect ERDS because Vermont Yankee maintains a continuous connection to the NRC.EN-EP-305 REV 3 ATTACHMENT 9.2 1OCFR50.54(q)

EVALUATION SHEET 2 OF 7 Procedure/Document Number: NA ý7Revision:

NA Equipment/Facillty/Other:

Vermont Yankee ERDS Title: NA EPOP-EOF-3546 Step 1.2 of Attachment 6 of EPOP-EOF-3546 instructs the Offsite Communicator to confirm that the IT Specialist has verified the ERDS connection with the NRC and to follow the Instructions in EN-EP-311 to perform the verification if the IT Specialist has not already performed the verification.

Step 3.1 of Attachment 6 of EPOP-EOF-3546 instructs the Offsite Communicator to not disconnect ERDS because Vermont Yankee maintains a continuous connection to the NRC.Step 1.2 of Attachment 6 of EPOP-EOF-3546 contains the following list of Notes:* Vermont Yankee maintains a continuous connection to the NRC using the Emergency Response Data System (ERDS)" Per 10CFR50.72 (a)(4) ERDS must be activated as soon as possible, but not later than one hour, after the initial declaration of an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY.

• Initial verification of the ERDS connection with the NRC will be performed by the IT Specialist.

If the IT Specialist is unable to verify the connection within the required time, then one of the following (in this order) will perform the verification:

EOF Off-site Communicator, EP Department Personnel.

Steps 1.2 and 2.2 of Attachment 14 of EPOP-EOF-3546 instructs the Offsite Liaisons to assist State personnel by Interpreting information/data, if necessary, for use with NRC ERDS, METPAC, Rascal and any other computer systems used for radiological assessment.

The New Hampshire and Massachusetts Offsite Liaisons mobilize to the State Emergency Operations Centers (EOCs). The Vermont Offsite Liaison is stationed at the EOF.EN-EP-311 EN-EP-311 provides for a secure network communications connection supporting the transmission of station parameters to the NRC in the event of a declared emergency.

The procedure provides the methodology for establishing the Virtual Private Network (VPN) communications link to the NRC for the transmission of ERDS data. The procedure also provides instructions for verification of connections for those Entergy plants which maintain 24/7 connectivity.

EPAD-0093 Attachment 4 of EPAD-0093 contains Instructions for ensuring that the NRC is notified prior to a drill or exercise in which ERDS will be used and Attachment 10 contains actions taken following a drill or exercise with respect to restoration of ERDS.AP-10049 AP-1 0049 identifies ERDS as equipment Important to emergency response.

ERDS is described as "a direct real time electronic transmission of the plant parameters to the NRC to assist them in monitoring the status of an emergency." ERDS Is identified as Category B equipment with no required compensatory measures.Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s)

Made to the NRC: Applicable Regulations:

Previous Commitments to the NRC -Per EN-LI-110, the licensing management system used for tracking NRC commitments (LRS) was searched as described in Part II and no results were found.10 CFR 50.47(b)(6)

-Emergency Communications:

Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.Site Compliance:

Section 7.0 of the Emergency Plan and EPOP-COMM-3504 describe the available communications equipment, the location of this equipment, and the procedures for communicating with on-site and off-site support groups including Federal and State authorities.

VY does not provide ERDS data to State authorities, but Instead maintains a continuous connection with the NRC.Because VY provides ERDS data to the NRC and not the State authorities, the VY Emergency Plan does not rely on the ability of the States to access ERDS for the provision of data. VY maintains the ability to provide more data (e.g., SFP parameters) to the ERO and State Representatives in the EOF than is available via ERDS.EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EVALUATION SHEET 3 OF 7 Procedure/Document Number: NA Revision:

NA Equipment/Facility/Other:

Vermont Yankee EROS Title: NA 10 CFR Part 50, Appendix E, Section VI -Emergency Response Data System: 1. The Emergency Response Data System (ERDS) is a direct near real-time electronic data link between the licensee's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters.

The ERDS supplements the existing voice transmission over the Emergency Notification System (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required.

The licensee shagl test the ERDS periodically to verify system availability and operability.

The frequency of ERDS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

2. Except for Big Rock Point and all nuclear power facilities that are shut down permanently or indefinitely, onsite hardware shall be provided at each unit by the licensee to interface with the NRC receiving system. Software, which will be made available by the NRC, will assemble the data to be transmitted and transmit data from each unit via an output port on the appropriate data system. The hardware and software must have the following characteristics:

a. Data points, if resident in the in-plant computer systems, must be transmitted for four selected types of plant conditions:

Reactor core and coolant system conditions; reactor containment conditions; radioactivity release rates; and plant meteorological tower data. A separate data feed is required for each reactor unit. While it is recognized that ERDS is not a safety system, it Is conceivable that a licensee's ERDS interface could communicate with a safety system. In this case, appropriate isolation devices would be required at these lnterfaces.ZThe data points, identified in the following parameters will be transmitted: (i) For pressurized water reactors (PWRs), the selected plant parameters are: (1) Primary coolant system: pressure, temperatures (hot leg, cold leg, and core exit thermocouples), subcoollng margin, pressurizer level, reactor coolant charging/makeup flow, reactor vessel level, reactor coolant flow, and reactor power; (2) Secondary coolant system: Steam generator levels and pressures, main feedwater flows, and auxiliary and emergency feedwater flows; (3) Safety injection:

High- and low-pressure safety Injection flows, safety Injection flows (Westinghouse), and borated water storage tank level; (4) Containment:

pressure, temperatures, hydrogen concentration, and sump levels; (5) Radiation monitoring system: Reactor coolant radioactivity, containment radiation level, condenser air removal radiation level, effluent radiation monitors, and process radiation monitor levels; and (6) Meteorological data: wind speed, wind direction, and atmospheric stability.(ii) For boiling water reactors (BWRs), the selected parameters are: (1) Reactor coolant system: Reactor pressure, reactor vessel level, feedwater flow, and reactor power; (2) Safety injection:

Reactor core isolation cooling flow, high-pressure coolant injection/high-pressure core spray flow, core spray flow, low-pressure coolant injection flow, and condensate storage tank level; (3) Containment:

drywell pressure, drywell temperatures, drywell sump levels, hydrogen and oxygen concentrations, suppression pool temperature, and suppression pool level; (4) Radiation monitoring system: Reactor coolant radioactivity level, primary containment radiation level, condenser off-gas radiation level, effluent radiation monitor, and process radiation levels; and (5) Meteorological data: Wind speed, wind direction, and atmospheric stability.

b. The system must be capable of transmitting all available ERDS parameters at time intervals of not less than 15 seconds or more than 60 seconds. Exceptions to this requirement will be considered on a case by case basis.c. All link control and data transmission must be established in a format compatible with the NRC receiving systenf-P as configured at the time of licensee implementation.

3. Maintaining Emergency Response Data System: a. Any hardware and software changes that affect the transmitted data points identified in the ERDS Data Point Ubrar9 (site specific data base residing on the ERDS computer) must be submitted to the NRC within 30 days after the changes are completed.

b. Hardware and software changes, with the exception of data point modifications, that could affect the transmission format and computer communication protocol to the ERDS must be provided to the NRC as soon as practicable and at least 30 days prior to the modification.

c. In the event of a failure of the NRC supplied onsite modem, a replacement unit will be furnished by the NRC for licensee installation.

4. Implementing the Emergency Response Data System Program: EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR5O.54(q)

EVALUATION SHEET 4 OF 7 Procedure/Document Number: NA 7 Revision:

NA EquipmentIFacllity/Other:

Vermont Yankee ERDS Title: NA a. Each licensee shall develop and submit an ERDS implementation program plan to the NRC by October 28, 1991. To ensure compatibility with the guidance provided for the ERDS, the EROS Implementation program plan,!Q must include, but not be limited to, information on the licensee's computer system configuration (i.e., hardware and software), interface, and procedures.

b. Licensees must comply with appendix E to part 50, section V.c. Licensees that have submitted the required information under the voluntary ERDS Implementation program will not be required to resubmit this information.

The licensee shall meet the implementation schedule of appendix E to Part 50,Section VI.4d.d. Each licensee shall complete implementation of the ERDS by February 13, 1993, or before initial escalation to full power, whichever comes later. Licensees with currently operational ERDS interfaces approved under the voluntary ERDS implementation program will not be required to submit another implementation plan and will be considered to have met the requirements for ERDS under appendix E to part 50, section VI. 1 and 2 of this part.Site Compliance; As described in the Emergency Plan and EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," VY currently maintains a continuous connection to the NRC using ERDS, thus satisfying the requirements of Section VI of 10 CAF Part 50, Appendix E.The requirements for ERDS in 10 CFR 50 Appendix E section VI.2 do not apply to nuclear power reactor licensees who have submitted a certificate of permanent cessation of operation of a nuclear power facility.

Per NRC memoranda dated 6/2/14 (ML1 4099A520), the objective of ERDS, since its Inception, has been to facilitate NRC monitoring of licensee response to the event and NRC assessment of the situation at the plant.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 and the requirements for ERDS in 10 CFR 50 Appendix E section VI.2 will no longer apply. Because Section VI of Appendix E to 10 CFR Part 50 is not applicable to permanently shutdown facilities, the emergency plan, as modified, will continue to meet the applicable requirements.

10 CFR 50.72(aX4)

-ERDS Activation:

The licensee shall activate the Emergency Response Data System (ERDS) -as soon as possible but not later than one hour after declaring an Emergency Class of alert, site area emergency, or general emergency.

The ERDS may also be activated by the licensee during emergency drills or exercises if the licensee's computer system has the capability to transmit the exercise data.Paragraph 50.72(a)(4), which requires the licensee to activate ERDS for certain events, contains a footnote stating,"Requirements for ERDS are addressed in Appendix E,Section VI." Because VY maintains a continuous connection to ERDS, an initial verification of the ERDS connection with the NRC following declaration of an emergency is currently performed by the TSC IT Specialist.

If the TSC IT Specialist is unable to verify the connection within the required time, then one of the following (in this order) will perform the verification:

EOF Off-site Communicator, EP Department Personnel.

Because ERDS requirements are not applicable to facilities which have permanently ceased operations, there can be no required ERDS for such a facility to activate and the emergency plan, as modified, will continue to meet the applicable requirements.

10 CFR 50.72(c)(3)

-Continuous Communication:

Maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC.10 CFR 50.72(c)(3) requires a licensee to maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC. Section 7.6 of the Emergency Plan describes the Federal Telecommunications System (FTS) that provides the ENS which exists between the NRC Operations Center (NRCOC) and the Control Room, with extensions In the Communications Room and the NRC Room of the TSC. The ENS also utilizes a separate FTS line between the NRCOC and the EOF. These lines are available for continuous communications with the NRCOC.EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EVALUATION SHEET 5 OF 7 Procedure/Document Number: NA Revision:

NA Equipment[Facility/Other:

Vermont Yankee EROS Title: NA Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change: 10 CFR 50.47(b)(61

-Emeroencv Communications

• Systems are established for prompt communication among principal emergency response organizations.

• Systems are established for prompt communications to emergency response personnel.

Sections IV.E.9 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear In Section I.F of NUREG-0654 and the licensee's emergency plan.Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Regulatory Guide 1.219, "Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors' provides guidance for determining reductions in effectiveness.

Section 1.8 states: The 10 CFR 50.54(q) change process establishes a two-factor test to determine when a change to an emergency plan requires prior NRC approval.

First, the test assesses whether the emergency plan, as modified, would continue to comply with the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR Part 50. Second, the test assesses whether the proposed change would reduce the effectiveness of the emergency plan. These two tests are separate and distinct.

ff the licensee does not meet either test, it must obtain prior NRC approval.

Meeting the first test does not imply that the licensee has met the second test, nor does meeting the second test imply that the licensee has met the first test.REGULATORY GUIDE 1.219 TEST PART 1: (Does the channe comolv with reaulations?)

10 CFR 50.47(b)(6) requires licensees to maintain prompt communications among principal response organizations to emergency personnel and to the public.The VY Emergency Plan does not rely upon ERDS for transmission of Information or data to the State or local authorities or to the public. Section 7.0 of the emergency plan identifies the means of communication with State and local authorities.

This is accomplished via InForm, Nuclear Alert System, Mobile UHF Radio System, commercial telephone system, and facsimile.

EROS is not identified as a communication channel to State response organizations; it is one of the communication channels between VY and the NRC. Therefore, the removal of ERDS from the Emergency Plan would not affect the ability of VY to maintain prompt communication among principal response organizations, to emergency personnel, and to the public. Accordingly, compliance with 10 CFR 50.47(b)(6) would not be affected by the retirement of ERDS.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 requirements for ERDS are located in 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section VI, "Emergency Response Data System."Section VI(2) provides an exclusion for reactors that are permanently or indefinitely shut down. In the Statements of Consideration (SOC) for the ERDS final rule (50 Federal Register 50178, August 13, 1991) the NRC stated the objective of the rule was to provide a reliable and effective communication system that would allow the NRC to monitor critical parameters at operating reactors during an emergency.

The NRC identified that it has a responsibility in the event of a reactor accident to monitor the actions of the licensee and to promptly assess the situation at the plant. The NRC described ERDS as a supplement to the ENS. Recent guidance issued by the NRC Director of the Division of Preparedness and Response (ML14099A520) confirms that the requirement to maintain EROS in 10 CFR 50 Appendix E, Section VI does not apply to nuclear power reactor licensees who have submitted a certificate of permanent cessation of operation of a nuclear power facility.Following the removal of EROS from the Emergency Plan, the Emergency Plan would continue to comply with the provisions of Appendix E that would remain applicable to VY.Paragraph 50.72(a)(4), which requires the licensee to activate ERDS for certain events, contains a footnote stating,"Requirements for ERDS are addressed in Appendix E,Section VI. Because ERDS requirements are not applicable to facilities which have permanently ceased operations, the 50.72(a)(4)

ERDS activiation requirement is likewise inapplicable.

EN-EP-305 REV 3 ATTAHMEN 9.21 OCR5O.4(q)EVALATIO ATTACHMENT 9.2 10CFR50.54(q)

EVALUATION SHEET 6 OF 7 Procedure/Document Number: NA Revision:

NA Equipment/FacilitylOther:

Vermont Yankee EROS Title: NA Accordingly, the revised Emergency Plan that would reflect the retirement of ERDS would continue to comply with all applicable regulatory requirements.

REGULATORY GUIDE 1.219 TEST PART 2: (Is the chanoe a reduction in effectiveness?)

The current ERDS Data Point Library Reference File provides the ERDS data points. In a permanently defueled condition, the only valid data points remaining in the EROS Data Point Library Reference File are radiological effluent data, radiation monitoring data, reactor building pressure data, torus water level data and meteorological data. While some of this information could be used for emergency dose assessment and determination of public protective action recommendations, VY does not rely on ERDS for the provision of this data to the VY Emergency Response Facilities, the VY Emergency Response Organization (ERO), or to the offsite agencies.

VY provides this plant data to the oftsite authorities via numerous other means.The PCS automatically exports data to ERDS. Separately, the Process Computer System also provides the data to the Emergency Operations Facility (EOF), Technical Support Center (TSC) and Operations Support Center (OSC) via the Emergency Response Facilities Information System (ERFIS) and Plant Data System (PDS) screens In each facility.Therefore, the retirement of ERDS would not reduce the effectiveness of VY's ability to provide plant data to the Emergency Response Facilities.

The ERO and on-shift personnel also do not rely on ERDS to obtain plant data. The ERO's source of data is the plant computer system or directly from Control Room instrumentation, both of which remain available to the VY ERO In the TSC and the EOF. Similarly, the plant computer system and Control Room Instrumentation will remain available to the on-shift staff. Therefore, the retirement of ERDS would not reduce the effectiveness of VY's ability to communicate plant information to the ERO or on-shift staff.VY does not provide plant data to the States of Massachusetts, Vermont, or New Hampshire via ERDS. Instead, VY provides plant data to State personnel stationed at the EOF or at their respective EOCs. Parameters related to the SFP, including SFP water level, SFP water temperature, and SFP pump status are not available via ERDS. However, the data is currently available in the EOF, TSC and OSC via the PDS. This data would be available to ERO and State personnel in the EOF, TSC and OSC via the display screens. The VY Vermont Offsite Liaison is stationed at the EOF. The VY New Hampshire and Massachusetts Offsite Liaisons mobilize to the State Emergency Operations Centers (EOCs). EPOP-EOF-3546 instructs the Off site Liaisons to assist State personnel by Interpreting information/data, if necessary, for use with NRC ERDS, METPAC, Rascal and any other computer systems used for radiological assessment.

The VY Offsite Liaison positions are also maintained in the Post-Shutdown ERO and will continue to assist State personnel by interpreting information/data from the plant computer system. Consequently, retirement of ERDS would not reduce the effectiveness of VY's ability to communicate plant data to State response organizations.

NRC guidance dated 6/2/14 (ML14099A520) confirms that removing ERDS would not reduce the effectiveness of a licensee's emergency plan: '...the objective of ERDS, since its Inception, has been to facilitate NRC monitoring of licensee response to the event and NRC assessment of the situation at the plant. Providing ERDS data to the NRC is not an emergency planning function as defined in 10 CFR 50.54(q)(1

)(iii). Because a reduction in effectiveness requires a reduction of the licensee's capability to perform an emergency planning function and providing data to the NRC through ERDS is not an emergency planning function, removing ERDS would not reduce the effectiveness of the licensee's capability to perform an emergency planning function.

Accordingly, removing ERDS would not reduce the effectiveness of the licensee's plan." For all of the reasons discussed above, removing ERDS would not reduce the effectiveness of the VY Emergency Plan.A revised VY Emergency Plan that reflects the retirement of ERDS would continue to comply with the requirements of 10 CFR 50.47(b)(6), 50.72(c)(3), and the remaining applicable requirements of Appendix E to 10 CFR Part 50. Removal of ERDS does not represent a reduction in effectiveness to the Emergency Plan and can be implemented without prior NRC approval.ATTACHMENT 9.2 10CFR50.54(q)

EVALUATION SHEET 7 OF 7 IP rocedure/Document Number: NA Revision:

NA EN-EP-305 REV 3 Equipment/FacilitylOther:

Vermont Yankee ERDS Title: NA Part VI. Evaluation Conclusion Answer the following questions about the proposed change.I. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? EYES El NO 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in EYES El NO effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change? [:]YES 0 NO If questions 1 or 2 are answered NO. or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process(es).

Refer to step 5.6[81.Part VII. Signatures Preparer Name (Print) Preparer Signature Date: 12/04/2014 David L. Daigle ( ../ ,7 (Optional)

Reviewer Name (Print) Reviewer Signa -Date: ,ei'tK evieww "96- /Date.-App, ove~rre Psint., nature Date: M el e i n e e .... .... .,. --zl--,)/ /EN-EP-305 REV 3 ATTACHMENT 9.2 IOCFR50.54(q)

EvALuA-noN Procedure/Document Number: NA Revision:

NA Page I of 7 Equipment/Facility/Other:

Vermont Yankee ERDS Title: NA Part I. Description of Proposed Change: This evaluation has been revised to address comments from the Onsite Safety Review Committee (OSRC) review on 1/13/15.This evaluation addresses the retirement of the Emergency Response Data System (ERDS) and removal of ERDS from the Emergency Plan (Section 7.10), EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546,"Emergency Operations Facility/Recovery Center (EOF/RC)," EPAD-0093, "Emergency Planning Data Management," and AP-1 0049, "Equipment Important to Emergency Response" and the removal of Vermont Yankee from EN-EP-31 1," Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)." Part II. Description and Review of Licensing Basis Affected by the Proposed Change: The Emergency Plan (Rev. 53 and 54), UFSAR (Rev. 26), Technical Specifications (Rev. 271), and Technical Requirements Manual (TRM) (Rev. 53) were searched for the following keywords:

Emergency Response Data System and ERDS. Additionally, EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," EPAD-0093, "Emergency Planning Data Management," and AP-10049,"Equipment Important to Emergency Response" were searched for the following keywords:

Emergency Response Data System and ERDS. EN-EP-31 1," Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)" was searched for Vermont Yankee and VY.ERDS Is not identified in Technical Specifications or the Technical Requirements Manual.Per EN-LI-1 10, the licensing management system used for tracking NRC commitments (LRS) was searched for references to ERDS and no results were found.ERDS was identified in the following:

Emergencv Plan According to Section 7.10 of the VY Emergency Plan, "ERDS is a direct real-time electronic transmission of the following types of data to the NRC to assist them in monitoring the status of an emergency:

1) core and coolant system data, 2)containment building data, 3) radioactivity release data, and 4) site meteorological data. Vermont Yankee maintains a continuous ERDS connection with the NRC Operations Center." UFSAR Section 7.15.1 of the UFSAR (Rev. 26) states that the Process Computer System (PCS) exports data to an Emergency Response Data System (ERDS) function and that, once activated, EROS sends selected current plant data points to the NRC Operations Center on a periodic basis. Section 7.15.2, Item #4 states that the PCS data export feature shall support the following ERDS functions (resident on another system): Capable of being manually activated within one hour; Once activated, will establish data communications with the NRC ERDS computer system,; Transmit critical plant data in the proper format and protocol at time Intervals of not less than 15 seconds or more than 60 seconds, until the link is manually disconnected, and; If the data connection is lost, the ERDS Interface module is responsible for re-establishing communication with the ERDS computer.EPOP-TSC-3542 Step 1.2 of Attachment 2 of EPOP-TSC-3542 states that the TSC Manager is responsible for ensuring the IT Specialist has verified the ERDS connection.

Step 1.2 of Attachment 12 instructs the IT Specialist to verify the EROS connection per EN-EP-31 1. Step 1.2 of Attachments 2 and 12 of EPOP-TSC-3542 both contain the following list of Notes:* Vermont Yankee maintains a continuous connection to the NRC using the Emergency Response Data System (ERDS)" Per 1 OCFR50.72 (a)(4) ERDS must be activated as soon as possible, but not later than one hour, after the initial declaration of an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY.

• Initial verification of the ERDS connection with the NRC will be performed by the IT Specialist.

If the IT Specialist is unable to verify the connection within the required time, then one of the following (in this order) will perform the verification:

EOF Off-site Communicator, EP Department Personnel.

Steo 3.1 of Attachment 12 of EPOP-TSC-3542 instructs the IT Soecialist to not disconnect ERDS because Vermont EN-EP-305 REV 3 Ar"FACHMENT 9.2 10CFR50.54(q)

EvALuATiON Procedure/Document Number: NA Revision:

NA Page 2 of 7 Equipment/FacllitylOther:

Vermont Yankee ERDS Title: NA Yankee maintains a continuous connection to the NRC.EPOP-EOF-3546 Step 1.2 of Attachment 6 of EPOP-EOF-3546 instructs the Offsite Communicator to confirm that the IT Specialist has verified the ERDS connection with the NRC and to follow the Instructions in EN-EP-31 1 to perform the verification if the IT Specialist has not already performed the verification.

Step 3.1 of Attachment 6 of EPOP-EOF-3546 instructs the Offsite Communicator to not disconnect ERDS because Vermont Yankee maintains a continuous connection to the NRC.Step 1.2 of Attachment 6 of EPOP-EOF-3546 contains the following list of Notes: " Vermont Yankee maintains a continuous connection to the NRC using the Emergency Response Data System (ERDS)* Per 1 OCFR50.72 (a)(4) ERDS must be activated as soon as possible, but not later than one hour, after the initial declaration of an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY." Initial verification of the ERDS connection with the NRC will be performed by the IT Specialist.

If the IT Specialist Is unable to verify the connection within the required time, then one of the following (in this order) will perform the verification:

EOF Off-site Communicator, EP Department Personnel.

Steps 1.2 and 2.2 of Attachment 14 of EPOP-EOF-3546 instructs the Offsite Uaisons to assist State personnel by interpreting information/data, if necessary, for use with NRC ERDS, METPAC, Rascal and any other computer systems used for radiological assessment.

The New Hampshire and Massachusetts Offsite Liaisons mobilize to the State Emergency Operations Centers (EOCs). The Vermont Offsite Liaison is stationed at the EOF.EN-EP-311 EN-EP-311 provides for a secure network communications connection supporting the transmission of station parameters to the NRC in the event of a declared emergency.

The procedure provides the methodology for establishing the Virtual Private Network (VPN) communications link to the NRC for the transmission of ERDS data. The procedure also provides instructions for verification of connections for those Entergy plants which maintain 24/7 connectivity.

EPAD-0093 Attachment 4 of EPAD-0093 contains instructions for ensuring that the NRC is notified prior to a drill or exercise in which ERDS will be used and Attachment 10 contains actions taken following a drill or exercise with respect to restoration of ERDS.AP-1.0049 AP-10049 identifies ERDS as equipment important to emergency response.

ERDS Is described as "a direct real time electronic transmission of the plant parameters to the NRC to assist them in monitoring the status of an emergency." ERDS is identified as Category B equipment with no required compensatory measures.Part Ill. Describe How the Proposed Change bomplies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s)

Made to the NRC: Applicable Regulations:

Previous Commitments to the NRC -Per EN-LI-1 10, the licensing management system used for tracking NRC commitments (LRS) was searched as described in Part II and no results were found.10 CFR 50.47(b)(6)

-Emergency Communications:

Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.Site Compliance:

Section 7.0 of the Emergency Plan and EPOP-COMM-3504 describe the available communications equipment, the location of this equipment, and the procedures for communicating with on-site and off-site support groups including Federal and State authorities.

VY does not provide ERDS data to State authorities, but instead maintains a continuous connection with the NRC.Because VY provides ERDS data to the NRC and not the State authorities, the VY Emergency Plan does not rely on the ability of the States to access ERDS for the provision of data. VY maintains the ability to provide data to the ERO and State Representatives in the EOF. The data is available in the EOF via the Plant Display System (PDS). This data will continue to be available to State Representatives in the EOF via the display screens. If requested by the States, the information could also be provided to the State EOCs by VY administrative personnel in the EOF via email or fax.EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EVALUATION Procedure/Document Number: NA Revision:

NA Page 3 of 7 EquipmentlFacllity/Other:

Vermont Yankee ERDS Title: NA 10 CFR Part 50, Appendix E, Section W -Emergency Response Data System: 1. The Emergency Response Data System (ERDS) is a direct near real-time electronic data link between the licensee's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters.

The ERDS supplements the existing voice transmission over the Emergency Notification System (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required.

The licensee shall test the ERDS periodically to verify system availability and operability.

The frequency of ERDS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

2. Except for Big Rock Point and all nuclear power facilities that are shut down permanently or indefinitely, onsite hardware shall be provided at each unit by the licensee to Interface with the NRC receiving system. Software, which will be made available by the NRC, will assemble the data to be transmitted and transmit data from each unit via an output port on the appropriate data system. The hardware and software must have the following characteristics:

a. Data points, If resident in the in-plant computer systems, must be transmitted for four selected types of plant conditions:

Reactor core and coolant system conditions; reactor containment conditions; radioactivity release rates; and plant meteorological tower data. A separate data feed is required for each reactor unit. While It Is recognized that ERDS is not a safety system, it is conceivable that a licensee's EROS interface could communicate with a safety system. In this case, appropriate isolation devices would be required at these interfaces.zThe data points, Identified in the following parameters will be transmitted: (i) For pressurized water reactors (PWRs), the selected plant parameters are: (1) Primary coolant system: pressure, temperatures (hot leg, cold leg, and core exit thermocouples), subcooling margin, pressurizer level, reactor coolant charging/makeup flow, reactor vessel level, reactor coolant flow, and reactor power;, (2) Secondary coolant system: Steam generator levels and pressures, main feedwater flows, and auxiliary and emergency feedwater flows; (3) Safety injection:

High- and low-pressure safety Injection flows, safety injection flows (Westinghouse), and borated water storage tank level; (4) Containment:

pressure, temperatures, hydrogen concentration, and sump levels; (5) Radiation monitoring system: Reactor coolant radioactivity, containment radiation level, condenser air removal radiation level, effluent radiation monitors, and process radiation monitor levels; and (6) Meteorological data: wind speed, wind direction, and atmospheric stability.(ii) For boiling water reactors (BWRs), the selected parameters are: (1) Reactor coolant system: Reactor pressure, reactor vessel level, feedwater flow, and reactor power; (2) Safety injection:

Reactor core isolation cooling flow, high-pressure coolant injection/high-pressure core spray flow, core spray flow, low-pressure coolant injection flow, and condensate storage tank level; (3) Containment:

drywell pressure, drywell temperatures, dtywell sump levels, hydrogen and oxygen concentrations, suppression pool temperature, and suppression pool level; (4) Radiation monitoring system: Reactor coolant radioactivity level, primary containment radiation level, condenser off-gas radiation level, effluent radiation monitor, and process radiation levels; and (5) Meteorological data: Wind speed, wind direction, and atmospheric stability.

b. The system must be capable of transmitting aft available ERDS parameters at time intervals of not less than 15 seconds or more than 60 seconds. Exceptions to this requirement will be considered on a case by case basis.c. All link control and data transmission must be established in a format compatible with the NRC receiving system# as configured at the time of licensee implementation.

3. Maintaining Emergency Response Data System: a. Any hardware and software changes that affect the transmitted data points identified in the EROS Data Point LibraryA (site specific data base residing on the ERDS computer) must be submitted to the NRC within 30 days after the changes are completed.

b. Hardware and software changes, with the exception of data point modifications, that could affect the transmission format and computer communication protocol to the ERDS must be provided to the NRC as soon as practicable and at least 30 days prior to the modification.

c. In the event of a failure of the NRC supplied onsite modem, a replacement unit will be furnished by the NRC for licensee installation.

4. Implementing the Emergency Response Data System Program: a. Each licensee shall develop and submit an ERDS implementation program plan to the NRC by October 28, 1991. To EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EVALuATiON Procedure/Document Number: NA Revision:

NA Page 4 of 7 EquipmentlFacliity/Other:

Vermont Yankee ERDS Title: NA ensure compatibility with the guidance provided for the ERDS, the ERDS implementation program planuL must include, but not be limited to, information on the licensee's computer system configuration (i.e., hardware and software), interface, and procedures.

b. Licensees must comply with appendix E to part 50, section V.c. Licensees that have submitted the required information under the voluntary ERDS implementation program will not be required to resubmit this information.

The licensee shall meet the implementation schedule of appendix E to Part 50,Section VI.4d.d. Each licensee shall complete implementation of the EROS by February 13, 1993, or before initial escalation to full power, whichever comes later. Licensees with currently operational EROS interfaces approved under the voluntary ERDS implementation program will not be required to submit another Implementation plan and will be considered to have met the requirements for ERDS under appendix E to part 50, section VI. I and 2 of this pall.Site Compliance As described in the Emergency Plan and EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," VY currently maintains a continuous connection to the NRC using ERDS, thus satisfying the requirements of Section VI of 10 CRF Part 50, Appendix E.The requirements for ERDS in 10 CFR 50 Appendix E section VI.2 do not apply to nuclear power reactor licensees who have submitted a certificate of permanent cessation of operation of a nuclear power facility.

Per NRC memoranda dated 6/2/14 (ML14099A520), the objective of ERDS, since its inception, has been to facilitate NRC monitoring of licensee response to the event and NRC assessment of the situation at the plant.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 and the requirements for ERDS in 10 CFR 50 Appendix E section VI.2 will no longer apply. Because Section VI of Appendix E to 10 CFR Part 50 is not applicable to permanently shutdown facilities, the emergency plan, as modified, will continue to meet the applicable requirements.

10 CFR 50.72(a)(4)

-ERDS Activation:

The licensee shaft activate the Emergency Response Data System (ERDS) as soon as possible but not later than one hour after declaring an Emergency Class of alert, site area emergency, or general emergency.

The ERDS may also be activated by the licensee during emergency drills or exercises if the licensee's computer system has the capability to transmit the exercise data.Paragraph 50.72(a)(4), which requires the licensee to activate ERDS for certain events, contains a footnote stating,"Requirements for ERDS are addressed in Appendix E,Section VI." Because VY maintains a continuous connection to ERDS, an initial verification of the ERDS connection with the NRC following declaration of an emergency is currently performed by the TSC IT Specialist.

If the TSC IT Specialist is unable to verify the connection within the required time, then one of the following (in this order) will perform the verification:

EOF Off-site Communicator, EP Department Personnel.

Because ERDS requirements are not applicable to facilities which have permanently ceased operations, there can be no required ERDS for such a facility to activate and the emergency plan, as modified, will continue to meet the applicable requirements.

10 CFR 50.72(c)(3)

-Continuous Communication:

Maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC.10 CFR 50.72(c)(3) requires a licensee to maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC. Section 7.6 of the Emergency Plan describes the Federal Telecommunications System (FTS) that provides the ENS which exists between the NRC Operations Center (NRCOC) and the Control Room, with extensions in the Communications Room and the NRC Room of the TSC. The ENS also utilizes a separate FTS line between the NRCOC and the EOF. These lines are available for continuous communications with the NRCOC.Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change: 1A C FR ~F;l d7(h'(R'h

-(t~nmmt~nipntinn~

lo cFR -rn 47(b)[A) -Ems-ency Communications EN-EP-305 REV 3 ArrAcHMENT 9.2 10CFR50.54(q)

EvALuATION Procedure/Document Number: NA Revision:

NA Page 5 of7 I EqulpmentfFacilitylOther:

Vermont Yankee ERDS Title: NA* Systems are established for prompt communication among principal emergency response organizations.

• Systems are established for prompt communications to emergency response personnel.

Sections IV.E.9 of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear in Section II.F of NUREG-0654 and the licensee's emergency plan.Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Regulatory Guide 1.219, "Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors" provides guidance for determining reductions in effectiveness.

Section 1.8 states: The 10 CFR 50.54(q) change process establishes a two-factor test to determine when a change to an emergency plan requires prior NRC approval.

First, the test assesses whether the emergency plan, as modified, would continue to comply with the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR Part 50. Second, the test assesses whether the proposed change would reduce the effectiveness of the emergency plan. These two tests are separate and distinct.

If the licensee does not meet either test, it must obtain prior NRC approval.

Meeting the first test does not imply that the licensee has met the second test, nor does meeting the second test imply that the licensee has met the first test.REGULATORY GUIDE 1.219 TEST PART 1: (Does the change comply with regulations?)

10 CFR 50.47(b)(6) requires licensees to maintain prompt communications among principal response organizations to emergency personnel and to the publlc.The VY Emergency Plan does not rely upon ERDS for transmission of information or data to the State or local authorities or to the public. Section 7.0 of the emergency plan Identifies the means of communication with State and local authorities.

This is accomplished via InForm, Nuclear Alert System, Mobile UHF Radio System, commercial telephone system, and facsimile.

ERDS is not identified as a communication channel to State response organizations; it Is one of the communication channels between VY and the NRC. Therefore, the removal of ERDS from the Emergency Plan would not affect the ability of VY to maintain prompt communication among principal response organizations, to emergency personnel, and to the public. Additionally, data Is available in the EOF via the PDS. This data will continue to be available to State Representatives In the EOF via the display screens. If requested by the States, the information could also be provided to the State EOCs by VY administrative personnel in the EOF via email or fax. Accordingly, compliance with 10 CFR 50.47(b)(6) would not be affected by the retirement of ERDS.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 requirements for ERDS are located In 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section VI, "Emergency Response Data System."Section VI(2) provides an exclusion for reactors that are permanently or indefinitely shut down. In the Statements of Consideration (SOC) for the ERDS final rule (50 Federal Register 50178, August 13, 1991) the NRC stated the objective of the rule was to provide a reliable and effective communication system that would allow the NRC to monitor critical parameters at operating reactors during an emergency.

The NRC Identified that it has a responsibility in the event of a reactor accident to monitor the actions of the licensee and to promptly assess the situation at the plant. The NRC described ERDS as a supplement to the ENS. Recent guidance issued by the NRC Director of the Division of Preparedness and Response (ML1 4099A520)confirms that the requirement to maintain ERDS In 10 CFR 50 Appendix E, Section VI does not apply to nuclear power reactor licensees who have submitted a certificate of permanent cessation of operation of a nuclear power facility.Following the removal of ERDS from the Emergency Plan, the Emergency Plan would continue to comply with the provisions of Appendix E that would remain applicable to VY.Paragraph 50.72(a)(4), which requires the licensee to activate ERDS for certain events, contains a footnote stating,"Requirements for ERDS are addressed in Appendix E,Section VI. Because ERDS requirements are not applicable to'facilities that have permanently ceased operations, the 50.72(a)(4)

ERDS activation requirement is likewise inapplicable.

Accordingly, the revised Emergency Plan that would reflect the retirement of ERDS would continue to comply with all applicable regulatory requirements.

REGULATORY GUIDE 1.219 TEST PART 2: (Is the change a reduction in effectiveness?)

The current ERDS Data Point Library Reference File provides the ERDS data points. In a permanently defueled condition, the only valid data Ivoints remaining in the ERDS Data Point Library Reference File are radioloalcal effluent data. radiation EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EvALUATION Procedure/Document Number: NA Revision:

NA Page 6 of 7 Equlpment/Facility/Other:

Vermont Yankee ERDS Title: NA monitoring data, reactor building pressure data, torus water level data and meteorological data. While some of this information could be used for emergency dose assessment and determination of public protective action recommendations, VY does not rely on ERDS for the provision of this data to the VY Emergency Response Facilities, the VY Emergency Response Organization (ERO), or to the offsite agencies.

VY provides this plant data to the offsite authorities via numerous other means. The data is available in the EOF via the PDS. This data will continue to be available to State Representatives in the EOF via the display screens. If requested by the States, the information could also be provided to the State EOCs by VY administrative personnel in the EOF via email or fax.The PCS automatically exports data to ERDS. Separately, the Process Computer System also provides the data to the Emergency Operations Facility (EOF), Technical Support Center (TSC) and Operations Support Center (OSC) via the Emergency Response Facilities Information System (ERFIS) and PDS screens in each facility.

Therefore, the retirement of ERDS would not reduce the effectiveness of VY's ability to provide plant data to the Emergency Response Facilities.

The ERO and on-shift personnel also do not rely on ERDS to obtain plant data. The ERO's source of data Is the plant computer system or directly from Control Room instrumentation, both of which remain available to the VY ERO In the TSC and the EOF. Similarly, the plant computer system and Control Room instrumentation will remain available to the on-shift staff. Therefore, the retirement of ERDS would not reduce the effectiveness of VY's ability to communicate plant information to the ERO or on-shift staff.VY does not provide plant data to the States of Massachusetts, Vermont, or New Hampshire via ERDS. Instead, VY provides plant data to State personnel stationed at the EOF or at their respective EOCs. The data is available in the EOF, TSC and OSC via the PDS. This data would be available to ERO and State personnel in the EOF, TSC and OSC via the display screens. The VY Vermont Offsite Liaison is stationed at the EOF. The VY New Hampshire and Massachusetts Offsite Liaisons mobilize to the State Emergency Operations Centers (EOCs). EPOP-EOF-3546 instructs the Offsite Liaisons to assist State personnel by interpreting information/data, if necessary, for use with NRC ERDS, METPAC, Rascal and any other computer systems used for radiological assessment.

The VY Offsite Liaison positions are also maintained in the Post-Shutdown ERO and will continue to assist State personnel by interpreting information/data from the plant computer system. Consequently, retirement of ERDS would not reduce the effectiveness of VY's ability to communicate plant data to State response organizations.

NRC guidance dated 6/2/14 (ML14099A520) confirms that removing ERDS would not reduce the effectiveness of a licensee's emergency plan: '...the objective of ERDS, since its inception, has been to facilitate NRC monitoring of licensee response to the event and NRC assessment of the situation at the plant. Providing ERDS data to the NRC is not an emergency planning function as defined In 10 CFR 50.54(q)(1)(iil).

Because a reduction in effectiveness requires a reduction of the licensee's capability to perform an emergency planning function and providing data to the NRC through ERDS is not an emergency planning function, removing ERDS would not reduce the effectiveness of the licensee's capability to perform an emergency planning function.

Accordingly, removing ERDS would not reduce the effectiveness of the licensee's plan." For all of the reasons discussed above, removing ERDS would not reduce the effectiveness of the VY Emergency Plan.A revised VY Emergency Plan that reflects the retirement of ERDS would continue to comply with the requirements of 10 CFR 50.47(b)(6), 50.72(c)(3), and the remaining applicable requirements of Appendix E to 10 CFR Part 50. Removal of ERDS does not represent a reduction in effectiveness to the Emergency Plan and can be implemented without prior NRC approval.Part VI. Evaluation Conclusion Answer the following questions about the proposed change.I. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? OYES [1 NO 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in IOYES [I NO effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change? []YES 0 NO If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50,90. If questions 1 and EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR50.54(q)

EVALUATION Procedure/Document Number: NA Revision:

NA Page 7 of 7 Equipment/FacilityiOther:

Vermont Yankee ERDS Title: NA 2 are answered YES, and question 3 answered NO, implement applicable change process(es).

Refer to step 5.6[8].Part VII. Signatures Preparer Name (Print) Preparer Signature Date: 01/22/2015 David L. Daigle ký 4 7 0,20 (Optional)

Reviewer Name (Print) Reviewer Signature Date: Reviewer Name (Print) Reviewer Signature Date: Tom Sowdon ... 1-26-2015 Nuclear EP Project Manager ApproiPal

?6aney A prover Pigg wre Date: EP Manager or designee 1 IA/EN-EP-305 REV 3