ML15076A074

Vermont Yankee, Emergency Plan Change, Revision 55

ML15076A074
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
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)

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f EntergyEntergy Nuclear Operations, Inc.Vermont YankeeP.O. Box 0500185 Old Ferry RoadBrattleboro, VT 05302-0500Tel 802 258 4183Michael P. McKenneyEmergency Planning ManagerBVY 15-003February 23, 2015U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555SUBJECT:REFERENCE:Emergency Plan Change, Revision 55Vermont Yankee Nuclear Power StationDocket No. 50-271License No. DPR-28Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont YankeeNuclear Power Station -Issuance of Amendment to Renewed FacilityOperating License RE: Changes to the Emergency Plan (TAC NO.MF3668,)" dated February 4, 2015Dear Sir or Madam:In accordance with 10 CFR 50.54(q) Entergy Nuclear Operations, Inc. is providing Revision 55of the Vermont Yankee Nuclear Power Station Emergency Plan (Plan) as an attachment to thisletter. This revision of the Plan incorporates changes approved by the NRC in Reference 1. Thisrevision also includes several changes that were evaluated pursuant to 10 CFR 50.54(q)(3) thatwere determined not to require prior NRC approval. Included with this revision is a description ofthe changes and the 10 CFR 50.54(q) Screening and Evaluation Forms for those changesperformed 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 2Attachment: Emergency Plan Change, Revision 55cc: Mr. Daniel H. DormanRegional Administrator, Region 1U.S. Nuclear Regulatory Commission2100 Renaissance Blvd, Suite 100King of Prussia, PA 19406-2713Mr. James S. Kim, Project ManagerDivision of Operating Reactor LicensingOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionMail Stop 08D15Washington, DC 20555USNRC Resident InspectorEntergy Nuclear Vermont Yankee, LLC320 Governor Hunt Rd.Vernon, Vermont 05354Mr. Christopher Recchia, CommissionerVT Department of Public Service112 State Street -Drawer 20Montpelier, Vermont 05620-2601 BVY 15-003Docket No. 50-271Attachment 1Vermont Yankee Nuclear Power StationEmergency Plan Change, Revision 55 EMERGENCY PLANENTERGY VERMONT YANKEEVERNON, VERMONTREVISION 55PREPARER:REVIEWED:APPROVED:APPROVED:-MP McKenney 0 of 0 :91 Z. z2zzýrEmergenWP4annIn a er nt/Sign) DateOý-Site Sifetypoýý mm e (Print/Sign) AateM icha e l R o m eo ' ' 1: 1 --. 1 ,General Mal gn)Chris WaVmser P0 t we_- -Site Vibe Presildt (Print/Sign)DateDateEffective Date 02/05/15 ENTERGY VERMONT YANKEE EMERGENCY PLANREVISION SUMMARYDATE REVISION DESCRIPTION04/28/04 39 Replaced Framatome ANS services and the DE&S Mutual AssistanceAgreement with the Corporate Service Center from White Plains.Updated information about the NAS to the new NAS system that wasinstalled. Added Mechanical Maintenance to the Repair & CorrectiveActions section for the 60 min. response in Table 8-4. Removed theEOFC Asst. and Communications positions. Removed requirementfor 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 studyconducted in 2004. Updated Table 4.2 and Figures 4.3, 4.4 and 4.5based on 2000 census data per UFSAR Rev. 19. Updated Section 4.2for latest population figures per UFSAR Rev. 19. Joint News Centeractivation changed from SAE to Alert. Removed references to"typically filled by" titles and "designated alternates" due to change tofour teams. Deleted Table 8.1. Changed alternate Joint News Centerlocation from Marlborough, MA to Landmark College. RevisedFigure 6.3 for new OSC Communication Center location. RevisedFigure 6.4 for new EOF/RC Center Layout. Section 8.2.1 SRMresponsibilities revised. Section 8.2.2 TSC Coordinatorresponsibilities revised. Security Coordinator position reports to offsite command center instead of the TSC. Revised Figure 8.3.Removed requirement for TS Coordinator to appoint an OSCCoordinator due to four team assignments. Revised Section 9.0 torequire activation of the Joint News Center at the Alert. RevisedTable 9.1. Updated Appendix E with recent letters of agreement fromDOE/REAC and INPO. Deleted letters of agreement with DukeEngineering & Services for old alternate joint news center and YankeeRowe for lab sample analysis and decontamination services. UpdatedAppendix G with new procedures AP 3549 and OP 3550. Removedreference to JNC Guidelines which were replaced by OP 3550.Changed OP 3505 to AP 3505 and OP 3712 to AP 3712. DeletedSection 8.2.7 Radiological Coordinator. Section 8.2.6 revised RadAssistant responsibilities. Revised Table 8.4 to remove reference toRadiological Coordinator. Revised Figure 8.2 to delete RadiologicalCoordinator. Revised Figure 8.5 to delete Radiological Coordinatorand communicators. Replaced with Radio Operator and RP staff.Revised Figure 8.7 to reflect changes due to four team rotation.Emergency PlanRevision 55Revision SummaryPage i of xEntergy Vermont Yankee REVISION SUMMARY (Continued)DATE REVISION DESCRIPTION01/18/06 41 Incorporated changes per NRC Bulletin 2005-02 (ECL definitionchanges, Security drills, Hostile Action definitions). Changed "UnusualEvent" to "Notification of Unusual Event" to conform to industrystandards. Changed title -Director of Public Affairs to Manager ofCommunications. Changed reference from Plant Operations ReviewCommittee to On-Site Safety Review Committee. Letters ofagreement reviewed annually in conjunction with annual review of theE-Plan. Updated respiratory protection locations per RP changes.Updated letters of agreement for States, DOE-REAC/TS and VernonFire Department. Added letters of agreement for States regardingAlert & Notification System (ANS). Added OP 3548 and OP 3551 tolist of Implementing Procedures in Appendix G. Updated Appendix Hfor the implementation of the new siren system.06/22/06 42 Corrected Hostile Force definition -"overtly" had been omitted fromthe last revision (WT-VTY-2006-00000 CA#00463). Revised thermalrated power per License Amendment #229, issued March 2, 2006(CR-VTYLO-2006-0004 CA#23). Removed reference to grosselectrical output. Per Regulatory Information Summary 2003-18,Supplement 2, issued December 12, 2005, removed the requirementfor 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. Replacedthe annual INPO letter of agreement with the latest version. Updatedthe general letters of agreement with Vermont and New Hampshire.Added memorandum of understanding for Alert & Notification Systemwith Vermont and New Hampshire. Added new procedure, OP 3552,Activation and Operation of the Alternate Joint News Center.Emergency PlanRevision 55Revision SummaryPage ii of xEntergy Vermont Yankee REVISION SUMMARY (Continued)DATE REVISION DESCRIPTION10/10/07 43 Changed TLD (thermoluminescent device) references to DLR(dosimeter of legal record) per Radiation Protection change. Replacedthe annual INPO letter with the latest version. Updated the generalletters of agreement with Franklin Medical Center, BrattleboroMemorial Hospital, Rescue, Inc. Ambulance Service, Vernon FireDepartment, Brattleboro Fire Department, Vermont Yankee NuclearPower 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 toprocedures OP 3524, OP 3525 and OP 3531 which were incorporatedinto other procedures; added EN-EP-605, Corporate IncidentResponse Team. Changed Joint News Center to Joint InformationCenter throughout. Changed Figure 6.1 to reflect new location ofMassachusetts Region III EOC. Revised Figure 6.3 to removereference to the medical office and update Control Point personnelcontamination monitor label. Changed reference from VermontOperational Quality Assurance Manual to Entergy Quality AssuranceManual. Removed references to the Duty On Call Officer. Removedrequirement for Plant Certification for the TSC Coordinator. Changedreferences to "corporate-level" to reflect Entergy organization.Revised EOF Coordinator and Radiological Assistant responsibilitiesto reflect organizational changes. Changed "onsite assistance teams"to "repair and corrective action teams." Revised Figure 8.5 to indicatethat the EOF Coordinator is not needed for activation of the EOF.Removed references that required the TSC Coordinator to respond atthe Notification of Unusual Event level and revised the responsibility todirect and coordinate all emergency response efforts. Revised Table9.1 to reflect changes in the emergency response organizationstructure. Removed respiratory protection from the equipmentinventory for the EOF. Revised "Emergency Broadcast Stations" to"Emergency Alert System stations." Removed reference to theEngineering Support Group as a separate entity. The EngineeringSupport Group is part of the TSC. Fire Brigade Leader changed fromShift Technical Advisor to Field Support Supervisor on Table 8.4.Removed specific number of federal agencies available. Revised thereference to the TSC capacity. Revised the OSC Coordinator locationto direct the OSC. Removed "designee" to the SRM responsibility toapprove press releases. Removed switchboard from the EOF.Removed NID Assistant from the JIC. Revised Table 9.1 to reflectERO structure. Added the use of State Reception Center fordecontamination efforts.Emergency PlanRevision 55Revision SummaryPage iii of xEntergy Vermont Yankee REVISION SUMMARY (Continued)DATE REVISION DESCRIPTION02/06/08 44 Implementation of the Independent Spent Fuel Storage Installation(ISFSI). Include ISFSI Emergency Action Level (EAL) for Notificationof Unusual Event. Include definitions for ISFSI and ConfinementBoundary. Update sections, tables and figures for title changes due tofleet alignment. Facility activation procedures incorporated into facilityoperation procedures.08/21/08 45 Implementation of the fleet standard Emergency ResponseOrganization (ERO). Joint Information Center relocation.03/12/09 46 Reference to Federal Radiological Emergency Response Plan(FRERP) changed to National Response Framework (NRF). Editorialchanges. Rearrange OSC and EOF layouts. Annual Update ofLetters of Agreement -no content change. Additional sirens added toAppendix H. Add FVY reference numbers to letters cited in Table 8.4Note 1.12/15/09 47 Revised Section 5.0 to indicate that the revised Emergency ActionLevels are based on NUMARC/NESP-007 (NEI 99-01), "Methodologyfor Development of Emergency Action Levels", Rev. 5, dated February2008. Revised 6.2.3, Meteorological Capability, to reflect the as-builtelevations for the temperature instruments. Deleted reference to theUHF radio antennas being mounted on the primary meteorologicaltower in Section 7.3. Changed "Federal Radiological EmergencyResponse Plan" to "National Response Framework" on Figure 9.1.Revised paragraph 5 of Section 12.1.2, Communications Tests, toindicate the monthly NRC communications test is with theHeadquarters Operations Officer rather than the NRC Region I Office.Replaced the AP 3125 EAL Chart with the revised EAL charts inAppendix A. Replaced AP 3505, Emergency Preparedness Exercisesand Drills, with fleet procedures EN-EP-306, Drills and Exercises, andEN-EP-307, Threat Based Drills, in Appendix G. Corrected sirennumbers on the Siren List in Appendix H. Added the siren drawing forthe 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 & Assessmentof Operational Aspects functional area section. This change is beinginstituted to clarify specific coverage detail. Deleted the verbiage thatspecifies who the fire brigade consists of (FSS, 3 AO, and 1 Security)from the Fire Fighting functional area section. Added an (*) withcomment that "Position staffed in accordance with TechnicalRequirements Manual and administrative procedures". The change isbeing instituted to be consistent with the TRM and to simplify upkeepof the Emergency Plan document.Emergency PlanRevision 55Revision SummaryPage iv of xEntergy Vermont Yankee REVISION SUMMARY (Continued)DATE04/28/11REVISION DESCRIPTION50 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 toreflect current capabilities for outside analytical assistance andlaboratory facilities support. Updated letters of agreement for: State ofMassachusetts, State of New Hampshire, State of Vermont, VernonFire Department, Brattleboro Fire Department, and Institute of NuclearPower Operations. Updated memorandum of understanding for Stateof Massachusetts Alert & Notification System, State of New HampshireAlert & Notification System, and State of Vermont Alert & NotificationSystem.Emergency PlanRevision 55Revision SummaryPage v of xEntergy Vermont Yankee REVISION SUMMARY (Continued)Section 3.2: Actions in an Emergency, Step 75/24/12 51 Step 7 was revised from "Use the plant pager system to notify appropriatepersonnel... to "use the emergency notification system to notify appropriatepersonnel...Section 6.1.3: Emergency Operations FacilitylRecovery CenterAdded a statement to address ERO Augmentation at Alternate FacilitiesSection 8.4.1, Local ServiceAn editorial ct ange was made to this section to add Baystate to the name of FranklinMedical CenterTable 8.4, Mir imum Staffing Requirements for the ENVY EROTable 8.4 has I ieen updated to replace Security with the Fire Brigade for the functionalarea of "Rescu 3 Operations & First Aid", Changed Rad Waste Operator from ACRO toCROSection 9.1 Em .rgency Condition Recognition and ClassificationAdded a to address Emergency Declaration TimelinessSection 9.2.4 Goneral Emergency Response, Step IThis section was updated to refer to the Corporate Emergency Center located inJackson MS for tne EOF Manager to contact in a General Emergency for fleet support.Figure 9.1, Notifioation PlanFigure 9.1 notification plan has been updated to align with the implementation ofEverbridge and OF' 3540, (Control Room Actions During an Emergency) and showoperations as the initiator of the notificationsSection 10.4.4, Usa of Onsite Protective Equipment and SuppliesEditorial change to correct Iodine to Iodide.Section 10.6, Protective Actions for Onsite PersonnelAdded a statement for Protective Actions for Onsite PersonnelSection 12.1.2, Com rnunication TestsSection 12.1.2 has been updated to align with the Everbridge implementation atVermont Yankee and evise the wording for the weekly communication test.Appendix E -Letters of AgreementUpdated the follc wing letters (18 is newly added)o Letteo 4, Baystate Franklin Medical Centero Lette; 5, National Weather Service (NOAA)o Letter 6, Brattleboro Memorial Hospitalo Letter 7, Rescue Inc Ambulance Serviceo Letter 10, Institute of Nuclear Power Operationso Letter 11, Town of Vernono Letter -2, DOEo Letter 13, DOE-REAC/TSo Letter 14, Vermont Yankee Nuclear Power Corporationo Letter 1t3, Landmark CollegeAppendix G -Index of Emergency Plan Implementing Procedures and SupportPlanso Emergency Plan Implementing Procedureso Support Planso Corporate Support ProceduresEmergency PlanRevision 55Revision SummaryPage vi of xEntergy Vermont Yankee REVISION SUMMARY (Continued)Section 7.9 "Emergency Response Data System" Removed12/20/12 52 wording regarding activation within one hour of an alert andreplaced it with a statement for maintaining a continuousconnectionSection 8.1 "Normal Plant Organization" Updated the on shiftstaffing to include one (1) FSS, five (5) AOs, and one (1) Utilityemployee per the Vermont Yankee Nuclear Power Station On-ShiftStaffing AnalysisSection 8.2.3 "Shift Manager" Updated the last sentence of theparagraph to state "The immediate responsibilities of the ShiftManager include performing or delegating performance of thefollowing."Table 8.4 "Minimum Staffing Requirements for the ENVY ERO"Replaced SCRO with CRS in the Table and on note 4. Titlechange 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 NuclearPower Station On-Shift Staffing Analysis for composition of the5 person fire brigade* Note 4: Added FSS for performing initial dose assessmentAppendix A "Emergency Classification System and EmergencyAction Levels" -Added a cross reference to AP 3125, "EmergencyPlan Classification and Action Level Scheme" for EAL Charts andremoved the image of the EAL ChartAppendix G "Index of Emergency Plan Implementing Proceduresand Support Plans"* I1. Support Plans- Added Vermont Yankee Nuclear PowerStation On-Shift Staffing Analysis0 Corporate Support Plans: Added procedure EN-EP-302"Severe Weather Response" effective 11/5/12Emergency PlanRevision 55Revision SummaryPage vii of xEntergy Vermont Yankee REVISION SUMMARY (Continued)Section 8.1, Normal Plant Organization9/17/13 539 Updated AOs from 5 to 6* Deleted Utility personTable 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 ** toreference the note "May be provided by shift personnelassigned other functions" and added reference to note 1regarding the Fire Brigade being staffed lAW TRM, StaffingAnalysis and AP 0894.Figure 8.1 -Corrected the number on on shift AOs and added theField Support Supervisor (FSS)Appendix E, Letters of Agreement* Updated INPO letter for 2012* DOE -REAC/TS -Updated letter dated June 6, 2013. Theletter content remains unchanged.* Deleted letter 14 "Vermont Yankee Nuclear PowerCorporation" no longer valid as of 12/31/12Appendix G, Index of Emergency Plan Implementing Proceduresand Support Plans* Added Fleet Administrative Procedure references* Updated procedure references in accordance with theprocedure upgrade project numbering schemeEmergency PlanRevision 55Revision SummaryPage viii of xEntergy Vermont Yankee REVISION SUMMARY (Continued)Index12/19/13 54* Added 7.1 InForm Notification System3.2. Actions in an Emergency* Changed Nuclear Alert System to Emergency Notification System in step 5 fornotifying the three states6.2.6. Facilities and Equipment for Offsite Monitoring* Removed the reference to the James A. Fitzpatrick environmental laboratory7.1. InForm Notification System* Added a description for the InForm Notification System7.2. Nuclear Alert System* Changed the words "Is used" to "can be" used to describe the Nuclear AlertSystemFigure 7.1, Plant to State Notification Channels* Added a line for InformFigure 7.2, Coordination Channels with States" Added a line for InformSection 8.1. Normal Plant Organization* Removed the Field Support Supervisor from the Normal Plant OrganizationTable 8.4. Minimum Staffing Requirements for the ENVY ERO" Notification/Communication: changed Chem Tech to AO" Radiological Accident Assessment -Deleted Field Support Supervisor (FSS) andadded Chem Tech." Note 4 -Deleted FSS and added Chem TechFigure 8.1. Normal On-Shift Emergency Organization* Revised to match shift staffing in section 8.1 and remove the Field SupportSupervisor (FSS)Figure 9.1. Notification Plan* Changed NAS to Inform/NASAppendix E, Letters of Agreement* Letters of Agreement have been removed from this document and will bemaintained in the Emergency Plan Department files. A summary of theagreements has also been added.Appendix F, Evacuation Time Estimates* An evacuation time estimate summary has been removed from this document andthe 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 PlansEmergency PlanRevision 55Revision SummaryPage ix of xEntergy Vermont Yankee REVISION SUMMARY (Continued)DatePendingRefer to Change Summary identifying Emergency Plan changesassociated with NRC approval of BVY 14-018 and additional post-shutdown Emergency Plan changes evaluated via 50.54(q).Emergency PlanRevision 55Revision SummaryPage x of xEntergy Vermont Yankee TABLE OF CONTENTS1.0 INTRO DUCTIO N ........................................................................................................ 12.0 DEFINITIO NS ............................................................................................................. 23.0 SUM MARY OF EM ERG ENCY PLA N ................................................................... 63.1. Objectives ............................................................................................... 63.2. Actions In An Em ergency ........................................................................... 73.3. Em ergency Response Facilities .................................................................. 73.4. Mobilization ................................................................................................. 83.5. State Government Notification and Response ............................................ 83.6. Federal Governm ent Notification and Response ........................................ 93.7. Technical Support ...................................................................................... 94.0 THE AREA ............................................................................................................... 104.1. The Site ................................................................................................... 104.2. Area Characteristics, Land Use and Dem ography .................................... 104.3. Em ergency Planning Zones ...................................................................... 125.0 EMERGENCY CLASSIFICATION SYSTEM ...................................................... 255.1. Notification of Unusual Event .................................................................... 255.1.1. Unusual Event (Term inated) .................................................... 265.2. Alert ............................................................................................................... 265.3. Site Area Em ergency ............................................................................... 265.4. General Em ergency ................................................................................. 275.5. Emergency Classification System Review by State Authorities ................ 276.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT ............................. 286.1. Em ergency Response Facilities ............................................................... 286.1.1. Technical Support Center ........................................................ 286.1.2. The Operations Support Center ................................................ 296.1.3. Emergency Operations Facility/Recovery Center ...................... 306.1.4. Deleted ...................................................................................... 316.1.5. Joint Inform ation Center .......................................................... 316.1.6. Coordination of Radiological Data ............................................ 316.2. Assessm ent Capability ............................................................................. 326.2.1. Process M onitors ...................................................................... 326.2.2. Radiological M onitors ............................................................... 326.2.3. Meteorological Capability ......................................................... 336.2.4. Fire Detection Devices ............................................................. 346.2.5. Post-Accident Sam pling ........................................................... 346.2.6. Facilities and Equipm ent for Offsite M onitoring ......................... 347.0 COM M UNICATIO NS ........................................................................................... 407.1. InForm Notification System ...................................................................... 40Emergency PlanRevision 55Table of ContentsPage i of viiEntergy Vermont Yankee TABLE OF CONTENTS (Continued)7.2. Nuclear Alert System ............................................................................... 407.3. Utility Microwave and Radio Systems ...................................................... 417.4. Mobile UHF Radio System ......................................................................... 417.5. Plant Intercom System ............................................................................. 417.6. NRC Telephone System .......................................................................... 417.7. Commercial Telephone System ............................................................... 427.8. Emergency Power Supply for Communications ......................................... 427.9. Facsimile Transmission ............................................................................ 427 .10 .C e leted ................................................................................................... ..4 38.0 ORGANZATION .................................................................................................. 478.1. Normal Plant Organization ........................................................................ 478.2. Emergency Response Organization ........................................................ 478.2.1. Emergency Director .................................................................. 498.2.2. Emergency Plant Manager ...................................................... 508.2.3. S hift M anager .......................................................................... 518 .2 .4 .D e leted .................................................................................... ..5 18.2.5.. Operations Support Center Manager ......................................... 528.2.6 Radiological Assessment Coordinator ...................................... 538.2.7. Administration and Logistics Coordinator ................................. 548.2.8. Security Coordinator .................................................................. 548.2.9. Company Spokesperson .......................................................... 558.2.10. Decision Maker ........................................................................ 558.2.11. Engineering Support Group ...................................................... 558.3. Recovery Organization ............................................................................ 568.4. Extensions of Vermont Yankee Emergency Organization ........................ 578.4.1. Local Service ............................................................................. 578.4.2. Federal Government Support ................................................... 578.4.3. Additional Support ................................................................... 588.5. Coordination with State Government Authorities ...................................... 589.0 EMERGENCY R=ESPONSE .................................................................................. 699.1. Emergenc', Condition Recognition and Classification ............................... 699.2. Activation of the Emergency Organization ............................................... 699.2.1. NIotification of Unusual Event Response ................................... 709.2.2. Alert Response ........................................................................ 719.2.3. S.te Area Emergency Response ............................................... 729.2.4. Gmeral Emergency Response .................................................. 739.3. Emergency De-Escalation and Termination Criteria ................................. 7310.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES ................. 7810.1. Radiological Assessment ........................................................................... 7810 .1.1. D e le ted .................................................................................... ..7810.1.2. Vari;able Trajectory Atmospheric Dispersion/Dose ProjectionC apability ............................................................................... ..78Emergency PlanRevision 55Table of ContentsPage ii of viiEntergy Vermont Yankee TABLE OF CONTENTS (Continued)10.1.3. Evaluation of Offsite Air Samples ............................................. 7810.2. Protective Action Recommendation Criteria ............................................ 7910.3. Radiological Exposure Control .................................................................. 7910.4. Protective Measures ................................................................................. 8010.4.1. Site Personnel Accountability ................................................... 8010.4.2. Site Egress Control Methods .................................................... 8110.4.3. Decontamination Capability ...................................................... 8110.4.4. Use of Onsite Protective Equipment and Supplies .................... 8110.4.5. Fire Protection Equipment ........................................................ 8110.5. Aid to Affected Personnel ........................................................................ 8210.5.1. Medical Treatment .................................................................... 8210.5.2. Medical Transportation ............................................................. 8210.6. Protective Actions for Onsite Personnel .................................................... 8211.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION .......................... 9011.1. Emergency Notification ............................................................................. 9011.2. Public Notification ...................................................................................... 9011.3. Public Information ...................................................................................... 9112.0 MAINTAINING EMERGENCY PREPAREDNESS ............................................. 9312.1. Drills and Exercises ................................................................................. 9312.1.1. Radiation Emergency Drills and Exercises ............................... 9312.1.2. Com munication Tests ............................................................... 9312.1.3. Fire Drills .................................................................................. 9412.1.4. Medical Drills ............................................................................ 9412.1.5. Radiological Monitoring Drills .................................................... 9412.1.6. Health Physics Drills ................................................................. 9412.1.7. Security Drills ........................................................................... 9512.1.8. Scenarios .................................................................................. 9512.1.9. Evaluation of Exercises ............................................................ 9612.1.10. Emergency Plan Audit ............................................................. 9612.2. Training ...................................................................................................... 9712.3. Review and Updating of Plan and Procedures .......................................... 9712.4. Maintenance and Inventory of Emergency Equipment and Supplies ...... 9812.5. Responsibility for the Planning Effort ........................................................ 98Emergency PlanRevision 55Table of ContentsPage iii of viiEntergy Vermont Yankee TABLE OF CONTENTS (Continued)APPENDICESAPPENDIX AAPPENDIX BAPPENDIX CAPPENDIX DAPPENDIX EAPPENDIX FAPPENDIX GAPPENDIX HEmergency Classification System and Emergency Action LevelsEmergency Equipment(Deleted)Environmental Laboratory Analytical and Dosimetry ServicesLetters of AgreementEvacuation Time EstimatesIndex of Emergency Plan Implementing Procedures andSupport PlansPublic Notification SystemPaqe101102105106108110111115Emergency PlanRevision 55Table of ContentsPage iv of viiEntergy Vermont Yankee TABLE OF CONTENTS (Continued)LIST OF TABLESTable 4.1Table 4.2Table 4.3Table 7.1Table 8.1Table 8.2Table 8.3Table 8.4Table 9.1Table 10.1.1Table 10.1.2Table 10.2Table 10.3Table of Land Use2000 Population Distribution Within the 50-Mile EPZ of VermontYankeeVermont Yankee "Plume Exposure" Emergency Planning Zone (10Mile) ConsiderationsVermont Yankee Emergency Communications Matrix(Deleted)(Deleted)A Summary of Offsite CoordinationMinimum Staffing Requirements for the ENVY EROVermont Yankee Emergency ResponseEPA Protective Action GuidelinesRecommended Derived Intervention Level (DIL) or Criterion for EachRadionuclide GroupEmergency Dose LimitsEmergency Center Habitability and Protective Action CriteriaEmergency PlanRevision 55Table of ContentsPage v of viiEntergy Vermont Yankee TABLE OF CONTENTS (Continued)LIST OF FIGURESFigure 4.1Figure 4.2Figure 4.3Figure 4.4Figure 4.5Figure 4.6Figure 4.7Figure 4.8Figure 6.1Figure 6.2Figure 6.3Figure 6.4Figure 7.1Figure 7.2Figure 8.1Figure 8.2Figure 8.3Figure 8.4Figure 8.5Figure 8.6I Figure 8.7Vermont Yankee SitePopulation Center and Special Interest Areas Within the 50 Mile EPZ2000 Population Distribution Within 0-5 Miles of Vermont Yankee2000 Population Distribution Within 0-10 Miles of Vermont Yankee2000 Population Distribution Within 10-50 Miles of Vermont YankeeSector Nomenclature for Vermont Yankee Plume Exposure EPZVermont Yankee Plume Exposure Emergency Planning ZoneVermont Yankee 50 Mile Ingestion Pathway Emergency Planning ZoneLocation of State and Company Emergency Operating Centers AroundVermont YankeeTechnical Support Center LayoutOperations Support Center LayoutEmergency Operations Facility/Recovery Center LayoutPlant to State Notification ChannelsCoordination Channels with StatesDefueled On-Shift Emergency OrganizationVermont Yankee Defueled Emergency Management OrganizationDefueled Technical Support Center Emergency Organization(Deleted)Defueled Emergency Operations Facility Organization(Deleted)Defueled Joint Information Center OrganizationEmergency PlanRevision 55Table of ContentsPage vi of viiEntergy Vermont Yankee TABLE OF CONTENTS (Continued)LIST OF FIGURES (Continued)Figure 9.1Figure 10.1Figure 10.2Figure 10.3Notification Plan(Deleted)Field Sample Thyroid Dose NomogramMedical Facilities within 50 Miles of Vermont Yankee Capable OfHandling Emergency Medical CasesEmergency PlanRevision 55Table of ContentsPage vii of viiEntergy Vermont Yankee

1.0 INTRODUCTION

In the event of an emergency at the Vermont Yankee Nuclear Power Station, officials fromVermont Yankee, local towns, the states of Vermont, New Hampshire and Massachusetts,as well as federal assistance resources, are mobilized to assess conditions and protect thehealth and safety of the public. This document outlines the emergency response actionsthat are taken by Vermont Yankee and the manner in which this response interfaces withoffsite response actions.This Emergency Plan is only a part of the overall response to an emergency at VermontYankee. Each community within about a 10-mile radius of the plant and the states(Massachusetts, New Hampshire, and Vermont) have developed emergency responseplans to be implemented if the need arises. In addition, federal agencies have specifiedtheir nuclear power plant emergency response roles and capabilities in the NationalResponse Framework (January 2008).The objective of this document is to outline the overall response of the Company to anemergency at the site. If an abnormal situation develops, automatic initiation of plant safetysystems takes place and plant operators take corrective action according to specificemergency operating procedures. The purpose of these emergency operating proceduresis to describe corrective actions necessary to restore normal plant safety margins. Theemergency operating procedures also lead to the activation of the Emergency Plan inaccordance with a prescribed set of emergency implementing procedures. The EmergencyPlan summarizes Vermont Yankee's emergency implementing procedures and thereby theoverall response to an emergency at the site.Emergency PlanRevision 55Page 1 of 123Entergy Vermont Yankee 2.0 DEFINITIONSAlert- Events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event that involvesprobable life threatening risk to site personnel or damage to site equipment because ofHOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.I Assessment Actions -Those actions which are taken to effectively define the emergencysituation necessary for decisions on specific emergency measures.Code Red -A Security related contingency requiring the activation of the SecurityResponse Team. This contingency shall, as a minimum cause a Notification of UnusualEvent to be announced.Committed Dose Equivalent (CDE) -The dose equivalent to organs or tissues ofreference (e.g., thyroid) that will be received from an intake of radioactive material by anindividual during the 50 year period following the intake.Confinement Boundary -The barrier(s) between areas containing radioactive substancesand the environment.Corrective Actions -Those emergency measures taken to ameliorate or terminate anemergency situation.Emergency Action Levels -Specific instrument readings, system or event observationand/or radiological levels which initiate event classification, notification procedures,protective actions, and/or mobilization of the emergency response organization. These arespecific threshold readings or observations indicating system failures or abnormalities.Emergency Assistance Personnel -Vermont Yankee personnel who are assigned a rolein the Emergency Response Organization.Emergency Classification -Emergencies are classified into four categories,NOTIFICATION OF UNUSUAL EVENT, ALERT, SITE AREA EMERGENCY andGENERAL EMERGENCY.Emergency Implementing Procedure -Specific action taken by the plant staff to activateand implement this Emergency Plan.Emergency Operations Centers -Areas designated by the state/local representatives asEmergency Plan assembly areas for their respective staffs.Emergency Operating Procedures -The outline of specific corrective actions to be takenby plant operators in response to abnormal operating conditions.Emergency PlanRevision 55Page 2 of 123Entergy Vermont Yankee Emergency Operations Facility -A center established to coordinate the deployment ofemergency response personnel, to evaluate offsite accident conditions and to maintaincommunications with offsite authorities.Emergency Planning Zone -The areas for which planning is recommended to assurethat prompt and effective actions can be taken to protect the public in the event of anaccident. The two zones are the 10-mile radius plume exposure pathway zone and the50-mile radius ingestion pathway zone.Emergency Response Organization -Organization comprised of Emergency AssistancePersonnel who would respond and assist in a classified emergency situation.Engineering Support Group -An engineering group established to provide emergencysupport for plant assessment and recovery operations.Gai-Tronics -An intra-site station operation and public address system which consists ofspeakers and microphones located in areas vital to the operation of the station. Thesystem has four channels which provide separate and independent page andintercommunication capabilities.General Emergency -Events are in progress or have occurred which involve actual orimminent substantial core degradation or melting with potential for loss of containmentintegrity 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 Guidelineexposure levels offsite for more than the immediate site area.Hostile Action -An act toward an NPP or its personnel that includes the use of violentforce to destroy equipment, takes hostages, and/or intimidate the licensee to achieve anend. 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 intentmay be included. HOSTILE ACTION should not be construed to include acts of civildisobedience 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 actsbetween individuals in the owner controlled area).Hostile Force -One or more individuals who are engaged in a determined assault overtlyor by stealth and deception, equipped with suitable weapons capable of killing, maiming, orcausing destruction.Independent Spent Fuel Storage Installation (ISFSI) -A complex that is designed andconstructed for the interim storage of spent nuclear fuel and other radioactive materialsassociated with spent fuel storage.Ingestion Exposure Pathway -The pathway in which individuals receive a radiation dosedue to internal deposition of radioactive materials from ingestion of contaminated water,foods, or milk.Emergency PlanRevision 55Page 3 of 123Entergy Vermont Yankee Joint Information Center -A center dedicated to the news media for the purpose ofdisseminating and coordinating information concerning accident conditions. Activitiesconducted within this center will be the responsibility of the Company Spokesperson.Notification of Unusual Event -Events are in progress or have occurred which indicate apotential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite responseor monitoring are expected unless further degradation of safety systems occurs.Operations Support Center -An emergency center established for available skilledemergency personnel (i.e., additional operations and support personnel). The OperationsSupport Center Manager directs activities within this center.Plume Exposure Pathway -The pathway in which individuals receive a radiation dosedue to: a) whole body external exposure due to gamma radiation from the plume and fromdeposited material; and b) inhalation exposure from the passing radioactive plume.Projected Dose -This is the amount of radiation dose estimated at the onset of anyaccidental radiological release. It includes all the radiation dose the individual wouldreceive for the duration of the release assuming that no protective measures wereundertaken.Protective Action -Those emergency measures taken to effectively mitigate theconsequences of an accident by minimizing the radiological exposure that would likelyoccur if such actions were not undertaken.Protective Action Guides -Projected radiological dose values to the public which warrantprotective actions following an uncontrolled release of radioactive materials. Protectiveactions would be warranted provided the reduction in the individual dose is not offset byexcessive risks to individual safety in implementing such actions.Recovery Actions -Those actions taken after the emergency has been controlled in orderto restore safe plant conditions.Recovery Center -An area established within the Emergency Operations facility for thepurpose of planning recovery actions. The Emergency Director directs the activities of thiscenter.Severe Accident Management -Process that management uses to evaluate and respondto an accident that has deteriorated to a condition where the EOPs are exited and theSevere Accident Guidelines are used.Site -That property within the fenced boundary of Vermont Yankee which is owned by theCompany.Emergency PlanRevision 55Page 4 of 123Entergy Vermont Yankee Site Area Emergency -Events are in progress or have occurred which involve an actualor likely major failures of plant functions needed for protection of the public or HOSTILEACTION that results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access toequipment needed for the protection of the public. Any releases are not expected to resultin exposure levels which exceed EPA Protective Action Guideline exposure levels beyondthe site boundary.Technical Support Center -An in-plant center established in close proximity to theControl Room that has the capability to acquire plant parameters for post-accidentevaluation by technical and recovery assistance personnel. The Emergency PlantManager directs activities within this center.Total Effective Dose Equivalent (TEDE) -The sum of the deep dose equivalent fromexternal sources and the committed effective dose equivalent from internal exposures.Unusual Event (Terminated) -A condition that warrants a Notification of Unusual Eventdeclaration, but was immediately rectified, such that the condition no longer existed by thetime of declaration. The event or condition did not affect personnel onsite or the publicoffsite, or result in radioactive releases requiring offsite monitoring.Emergency PlanRevision 55Page 5 of 123Entergy Vermont Yankee 3.0 SUMMARY OF EMERGENCY PLAN3.1. ObjectivesSafety systems at Vermont Yankee are designed to prevent and/or mitigate accidentalradioactive releases. Accordingly, the probability for a release of radioactivity resulting in apublic hazard is very small. As a precautionary measure, however, this Emergency Planspecifies response actions if the safety systems are degraded or fail.The purpose of this Emergency Plan is to classify emergencies according to severity, toassign responsibilities, and to clearly outline the most effective actions to safeguard thepublic and plant personnel in the unlikely event of an incident at Vermont Yankee. Detailedemergency procedures at Vermont Yankee are followed by plant personnel to notify andactivate the onsite and offsite emergency organizations. These procedures aresummarized in this Emergency Plan.The basic objectives of this plan are:1) To establish a system for identification and classification of the emergency conditionand initiation of response actions;2) To establish an organization for the direction of activity within the plant to limit theconsequences of the incident;3) To establish an organization for control of onsite and offsite surveillance activities toassess the extent and significance of any uncontrolled release of radioactivematerial;4) To identify facilities, equipment and supplies available for emergency use;5) To establish an engineering support organization to aid the plant personnel inlimiting 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 andagencies for offsite emergency response;8) To develop a communications network between the plant and offsite authorities toprovide prompt notification of emergency situations;9) To develop a training and Emergency Plan exercise program to assure constanteffectiveness of the plan; and10) To keep the public informed in a timely manner to preclude misinformation andbolster confidence in the emergency response.Emergency PlanRevision 55Page 6 of 123Entergy 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, andGeneral Emergency. Depending on the emergency classification, different levels of plantand offsite response are required. Activation of emergency facilities takes place inaccordance with the classification of emergency response.3.2. Actions In An EmergencyIf an emergency condition develops, the Shift Manager assumes the responsibilities forinitiating emergency actions to limit the consequences of the incident and to bring the plantinto 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 theInForm 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 andTable 9.1;8) Depending on the emergency classification, initiate the procedures which activatethe Technical Support Center, the Emergency Operations Facility/Recovery Center,the Operations Support Center, and the Joint Information Center; and9) Direct and coordinate all emergency response efforts until overall responsibility isassumed by the Emergency Director.3.3. Emergency Response FacilitiesThe emergency response facilities, which are utilized by the emergency responseorganization, are described in Section 6.0. Depending on the emergency classification,different facilities are activated and utilized. Key site and offsite personnel are quicklydispatched to these facilities to perform accident assessments, implement correctiveactions, analyze accident data, and provide public information support.Emergency PlanRevision 55Page 7 of 123Entergy Vermont Yankee 3.4. MobilizationThe mobilization scheme is based on the emergency notification system shown inFigure 9.1. Table 9.1 identifies the personnel notified. The notification system utilizes theplant public address system (Gai-Tronics), dedicated telephone lines, and radio pagerdevices (beepers) to notify and mobilize personnel. Key Vermont Yankee and supportpersonnel carry pagers to expedite the mobilization process during off-hours. Dependingupon the emergency classification, different levels of mobilization are implemented. Themobilization scheme ensures that specific technical disciplines identified by Table B-1 ofNUREG-0654 can be augmented within appropriate time frames. Table 8.4 outlines theminimum staffing requirements for the Emergency Response Organization at VermontYankee. Table 9.1 summarizes the response to the four classes of emergencies describedin Section 5.0.3.5. State Government Notification and ResponseVermont Yankee's Emergency Plan interfaces with the state emergency response plans ofVermont, New Hampshire and Massachusetts. Local town governments, in coordinationwith the emergency management agencies of these states, have plans, which if the needarises, contain instructions to carry out specific protective measures dependent uponvarious emergency conditions.Vermont Yankee is responsible for conveying specific accident information, radiologicalassessment information, and protective action recommendations to the State of Vermont,State of New Hampshire, and Commonwealth of Massachusetts. It is the responsibility ofeach respective state Department of Public Health to evaluate this information and makeappropriate recommendation regarding public protective actions in accordance with theirplans and procedures.A cooperative arrangement exists among the Vermont, New Hampshire andMassachusetts State authorities and Vermont Yankee Nuclear Power Station concerningradiological emergency preparedness. Vermont Yankee's emergency classification systemand notification messages are reviewed and approved by these states in accordance withthe terms specified in the Letter of Agreement found in Appendix E. Each state iscommitted to dispatching representatives to the plant's Emergency OperationsFacility/Recovery Center when conditions warrant. Vermont Yankee's Joint InformationCenter provides the opportunity for joint utility, state and federal press briefings to be held.Emergency PlanRevision 55Page 8 of 123Entergy Vermont Yankee 3.6. Federal Government Notification and ResponseAs soon as an event is classified into one of the four categories of emergencies, notificationto the NRC is made using the Emergency Notification System. Once notified of anemergency, the NRC evaluates the situation and determines the appropriate NRCresponse. Depending on the severity of the accident and the emergency classificationdeclared, the NRC activates their incident response operations in accordance with the NRCIncident Response Plan. The NRC notifies the Federal Emergency Management Agency(FEMA) and other appropriate federal agencies to activate the federal emergency responseorganization in accordance with the National Response Framework (NRF). The NRFmakes available the resources and capabilities of federal agencies to support plant, stateand local governments. Principal participants are the NRC, FEMA, Department of Energy(DOE), and Environmental Protection Agency (EPA).3.7. Technical SupportTechnical and manpower support are provided to the Vermont Yankee plant throughsupport plans listed in Appendix G. Support beyond this level is arranged through theInstitute of Nuclear Power Operations (INPO).Emergency PlanRevision 55Page 9 of 123Entergy Vermont Yankee 4.0 THE AREA4.1. The SiteVermont Yankee Nuclear Power Station is located on the west bank of the ConnecticutRiver immediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont.The Vermont Yankee Nuclear Power Station ceased power operations and is permanentlydefueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). The station, shown inFigure 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 VermontYankee property for which it has perpetual rights and easements from the owner, NewEngland Power Company.On January 12, 2015, ENO submitted a certification that a determination to permanentlycease power operations was made on December 29, 2014, pursuant to 10 CFR50.82(a)(1)(i). ENO has submitted written certification to the NRC, in accordance with 10CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuelhas 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 longerauthorizes operation of the reactor or emplacement or retention of fuel into the reactorvessel, as specified in 10 CFR 50.82(a)(2).With irradiated fuel being stored in the Spent Fuel Pool and the ISFSI, the reactor, reactorcoolant system and secondary system are no longer in operation and have no functionrelated to the storage of the irradiated fuel. Therefore, the postulated accidents involvingfailure or malfunction of the reactor and reactor coolant system or secondary system are nolonger applicable.4.2. Area Characteristics, Land Use and DemograDhyThe site, also shown in Figure 4.1, is bounded by the Connecticut River (Vernon Pond) onthe east, by farm and pasture land mixed with wooded areas on the north and south, andby the town of Vernon on the west. Warwick and Northfield State Forests (approximately 8miles southwest of the site), Green Mountain National Forest (approximately 18 milessouthwest of the site) and the Pisgah Mountain Range (northeast of the site) limit thepopulation density and land use within a 50-mile radius of the site. Most of the land aroundthe 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 smallvillages. The primary agricultural crop is silage corn, which is stored for year-round feed formilk cows.Emergency PlanRevision 55Page 10 of 123Entergy Vermont Yankee The nearest house is 1,300 feet from the Reactor Building and is one of several west of thesite. The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500feet from the Reactor Building. The nearest hospital, Brattleboro Memorial, isapproximately five (5) miles north-northwest from the site. The nearest dairy farm isapproximately 1/2-mile northwest of the site. Additional dairy farms are located within a5-mile radius of the plant. A nursing home is located 2 miles south of the plant. Theseareas have been noted since they have required special planning consideration by offsiteauthorities 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 wasestimated to be 126 people per square mile. Figures 4.3, 4.4, and 4.5 provide the 2000population distribution within a 5-, 10-, and 50-mile radius of the Vermont Yankee NuclearPower Station. Table 4.2 summarizes these data.Emergency PlanRevision 55Page 11 of 123Entergy Vermont Yankee 4.3. Emergency Planning ZonesThe NRC/EPA Task Force Report on Emergency Planning, "Planning Basis for theDevelopment of State and Local Government Radiological Emergency Response Plans inSupport of Light-Water Nuclear Power Plants" (NUREG-0396) established the size ofplanning zones for which predetermined emergency actions should be prepared. Theseplanning zones were selected based upon the knowledge of the potential consequences,timing and release characteristics of a spectrum of accidents (including core meltscenarios), regardless of the low probability of occurrence. As a result, an EmergencyPlanning Zone concept was developed, both for short-term plume exposure and for thelonger-term ingestion exposure pathways.Emergency Planning Zones (EPZs) are defined as the areas for which planning is neededto assure that prompt and effective actions can be taken to protect the public in the event ofan accident. The size of the Emergency Planning Zones represents the extent of detailedplanning which should be performed to assure an adequate response. Dependent uponthe severity of the accident, protective actions are generally limited to only portions of thedesignated 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 dividesthe planning zones into sectors of 22 1/2 degrees centered on the 16 standard compassdirections (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 milesradially outward from the plant.Vermont Yankee, for the purpose of radiological protection, is responsible for exercisingdirect 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 NewHampshire.In accordance with the recommended planning bases, Vermont Yankee has expanded itsprevious planning considerations by defining two Emergency Planning Zones. The plumeexposure EPZ, shown in Figure 4.7, is an area designated by the jurisdictional boundariesof those communities which are within a radial distance of 10 miles from the plant site. Thesize of the zone is based on the following considerations: 1) projected doses estimated formost 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 ofresponse efforts in the event that it is necessary; 3) planning within this area recognizes alljurisdictional restraints imposed by the zone designation. Table 4.3 lists the localcommunities that are affected by this designation, the wind direction which wouldpotentially affect these communities if a release occurs, and the sector/distanceidentification representing each of these communities. As specified in the state plans,communities within the plume exposure EPZ are alerted if a major accident at VermontYankee occurs. Communities within this zone have their own local radiological responseplans.Emergency PlanRevision 55Page 12 of 123Entergy Vermont Yankee The ingestion exposure pathway Emergency Planning Zone, shown in Figure 4.8, is anarea within a 50-mile radius from the plant site. The size of the zone is based on the factthat the downwind range within which significant contamination could occur would generallybe limited to this distance because of wind shifts and travel periods. In addition, projecteddoses from contamination outside this zone would not exceed the Department of Healthand Human Services' ingestion pathway Protective Action guides. Four states (Vermont,New Hampshire, Massachusetts, and New York) are responsible for coordinating andimplementing protective actions within this area. Precautionary measures relative tolivestock feeds, milk products, garden produce, and potable water supplies areimplemented in this area to the extent dictated by the release conditions.Emergency PlanRevision 55Page 13 of 123Entergy Vermont Yankee TABLE 4.1TABLE OF LAND USE(Square Miles)Distance from SiteLand UseResidentialCommercial and IndustrialAgriculturalRoadPublicUndevelopedTOTAL0-10 Miles30.21.325.96.07.2243.4314.010-25 Miles79.27.7143.821.678.31318.41649.01-25 Miles109.49.0169.727.685.51561.81963.0Emergency PlanRevision 55Page 14 of 123Entergy Vermont Yankee TABLE 4.22000 POPULATION DISTRIBUTION WITHIN THE 50-MILEEPZ OF VERMONT YANKEEPOPULATION TOTALS BY ZONERingMiles0-11-22-33-44-55-1010-2020-3030-4040-50Population489249619371556344123954111005133847337525851123CumulativeMiles0-10-20-30-40-50-100-200-300-400-50Population4892985492264789919338731448782787256162501467373POPULATION TOTALS BY SECTORTotal PopulationTotal PopulationSector0-50 MilesSector0-50 MilesABCDEFGH(N)(NNE)(NE)(ENE)(E)(ESE)(SE)(SSE)462043642445230509399238918870114194160442JKLMNPQR(S)(SSW)(SW)(WSW)(W)(WNW)(NW)(NNW)458553120057326097828744288318551751221912Emergency PlanRevision 55Page 15 of 123Entergy Vermont Yankee TABLE 4.3VERMONT YANKEE"PLUME EXPOSURE" EMERGENCY PLANNING ZONE (10 MILE) CONSIDERATIONS1.2.3.4.5.1.2.3.4.5.1.2.3.4.5.6.7.COMMUNITIESINVOLVEDBrattleboro, VTDummerston, VTGuilford, VTHalifax, VTVernon, VTChesterfield, NHHinsdale, NHRichmond, NHSwanzey, NHWinchester, NHBernardston, MAColrain, MAGill, MALeyden, MANorthfield, MAWarwick, MAGreenfield, MAAPPROPRIATE SECTORIDENTIFICATION*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), Kand L (0-4), M, N, and P (0-3), Qand R (0-4)A and B (5-10), C (6-10)R, A, and B (0-6), C (0-4), D andE (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 WINDSBLOWING FROMESE -SSE -SSWNNE -SSEENE -SEALL DIRECTIONSSSE -WSWALL DIRECTIONSWSW-WNWSSW-WS -NWNNW- ENENNE-ENNW- NNEN-EWNW- NNEW-NNWN -NE*Numbers in parentheses represent approximate miles from plant.Emergency PlanRevision 55Page 16 of 123Entergy Vermont Yankee Vermont YankeeNuclear PowerStationVemonElementarySchoolGovernor"-,Hunt HouseiNA YALEtVemronElydrostationFigure 4.1Vermont Yankee SiteEmergency PlanRevision 55Page 17 of 123Entergy Vermont Yankee Figure 4.2Population Center and Special Interest Areas Within the 50 Mile EPZEmergency PlanRevision 55Page 18 of 123Entergy Vermont Yankee N(A)NNWWNW(P)w(N) 76(M)WSWENE(D)E5 (E)ESE(F)SSW(H)(J)SFigure 4.32000 Population DistributionWithin 0 -5 Miles of Vermont YankeeEmergency PlanRevision 55Page 19 of 123Entergy Vermont Yankee NWNW(P)w(N)(M)WSWENE(D)E(E)( ESE(F)(J) SFigure 4.42000 Population DistributionWithin 0 -10 Miles of Vermont YankeeEmergency PlanRevision 55Page 20 of 123Entergy Vermont Yankee N(A)WNW(P)ENE(D)E(E)ESE(F)(J) SFigure 4.52000 Population DistributionWithin 10 -50 Miles of Vermont YankeeEmergency PlanRevision 55Page 21 of 123Entergy 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 4.6Sector Nomenclature for Vermont YankeePlume Exposure EPZEmergency PlanRevision 55Page 22 of 123Entergy Vermont Yankee 0 5 10 15Figure 4.7Vermont Yankee Plume Exposure Emergency Planning ZoneOnly those portions of the communities that are within a 10-mile radius have been coveredby the Public Notification System. All communities within this EPZ Boundary designationhave developed an emergency plan.Emergency PlanRevision 55Page 23 of 123Entergy Vermont Yankee 0 10 20 30 40 50MilesFigure 4.8Vermont Yankee 50 Mile Ingestion PathwayEmergency Planning ZoneEmergency PlanRevision 55Page 24 of 123Entergy Vermont Yankee 5.0 EMERGENCY CLASSIFICATION SYSTEMThe wide spectrum of component or system failures, or other occurrences that couldpotentially reduce plant safety margins, needs to be categorized. For this reason, aclassification system has been defined which categorizes incidents according to severityinto 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 bycertain measurable and observable indicators of plant conditions called Emergency ActionLevels (EALs) listed in Appendix A. Emergency Action Levels defined in Appendix A aidthe operator in recognizing the potential of an incident immediately and assure that the firststep in the emergency response is carried out. The classification of the event may changeas the conditions change.The VY EALs and EAL bases were derived from example initiating conditions inNUMARC/NESP-007 (NEI 99-01), "Methodology for Development of Emergency ActionLevels", Rev. 5, dated February 2008. The EALs and bases have been modified inaccordance 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 EventEVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE APOTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANTOR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HASBEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIALREQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTEDUNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.Notification of Unusual Event conditions do not cause serious damage to the plant. Thepurpose of the Notification of Unusual Event declaration is to: 1) ensure that the first step inany response later found to be necessary has been carried out; 2) bring the operating staffto a state of readiness; and 3) ensure that appropriate offsite notifications have been madein the event that additional support is required.See Appendix A for a complete list of Emergency Action Levels corresponding to aNotification of Unusual Event.Emergency PlanRevision 55Page 25 of 123Entergy Vermont Yankee 5.1.1. Unusual Event (Terminated)If a condition that warrants a Notification of Unusual Event declaration has occurred, andwas immediately rectified such that the condition no longer existed by the time ofdeclaration, this Notification of Unusual Event classification is referred to as an UnusualEvent (Terminated).The event or condition did not affect personnel onsite or the public offsite, or result inradioactive releases requiring offsite monitoring.5.2. AlertEVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVEAN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THELEVEL OF SAFETY OF THE PLANT OR A SECURITY EVENT THATINVOLVES PROBABLE LIFE THREATENING RISK TO SITE PERSONNELOR DAMAGE TO SITE EQUIPMENT BECAUSE OF HOSTILE ACTION.ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALLFRACTIONS OF THE EPA PROTECTIVE ACTION GUIDELINE EXPOSURELEVELS.Plant response and offsite notifications associated with this event classification assure thatsufficient emergency response personnel, both onsite and offsite, are mobilized andrespond to event conditions. Actual releases of radioactivity which exceed TechnicalSpecification limits may be involved, thus radiation monitoring and dose projection may bean integral portion of the emergency response required. Plant emergency responsefacilities are activated at this classification.See Appendix A for a complete list of Emergency Action Levels corresponding to an Alert.5.3. Site Area EmergencyEVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVEAN ACTUAL OR LIKELY MAJOR FAILURES OF PLANT FUNCTIONSNEEDED FOR PROTECTION OF THE PUBLIC OR HOSTILE ACTIONTHAT RESULTS IN INTENTIONAL DAMAGE OR MALICIOUS ACTS; (1)TOWARD SITE PERSONNEL OR EQUIPMENT THAT COULD LEAD TOTHE LIKELY FAILURE OF OR; (2) THAT PREVENT EFFECTIVE ACCESSTO EQUIPMENT NEEDED FOR THE PROTECTION OF THE PUBLIC. ANYRELEASES ARE NOT EXPECTED TO RESULT IN EXPOSURE LEVELSWHICH EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURELEVELS BEYOND THE SITE BOUNDARY.Emergency PlanRevision 55Page 26 of 123Entergy Vermont Yankee The events included in this category represent a potential for offsite releases which couldimpact the public to the extent that protective actions may be necessary. The purpose ofthe Site Area Emergency declaration is to: 1) ensure that all plant emergency responseelements 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 interfacewith offsite governmental response organizations; and 5) provide updates for the publicthrough offsite officials.See Appendix A for a complete list of Emergency Action Levels corresponding to Site AreaEmergency.5.4. General EmergencyEVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVEACTUAL OR IMMINENT SUBSTANTIAL CORE DEGRADATION ORMELTING WITH POTENTIAL FOR LOSS OF CONTAINMENT INTEGRITYOR HOSTILE ACTION THAT RESULTS IN AN ACTUAL LOSS OFPHYSICAL CONTROL OF THE FACILITY. RELEASES CAN BEREASONABLY EXPECTED TO EXCEED EPA PROTECTIVE ACTIONGUIDELINE EXPOSURE LEVELS OFFSITE FOR MORE THAN THEIMMEDIATE SITE AREA.The purpose of the General Emergency declaration is to: 1) ensure that appropriate offsiteofficials are adequately advised as to the extent of plant degradation; 2) provideconsultation with offsite authorities in establishing appropriate protective actions for thepublic; 3) provide updates for the public through offsite authorities; and 4) ensure that allemergency response organizations and resources are being applied to accident mitigation.See Appendix A for a complete list of Emergency Action Levels corresponding to a GeneralEmergency.5.5. Emergency Classification System Review by State AuthoritiesThe emergency classification system specified above, as well as the EALs presented inAppendix A, is reviewed with the state authorities of Vermont, New Hampshire, andMassachusetts.Emergency PlanRevision 55Page 27 of 123Entergy Vermont Yankee 6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENTFollowing the declaration of an emergency, the activities of the emergency responseorganization are coordinated in a number of emergency response facilities. Figure 4.1shows the relative locations of Vermont Yankee's onsite emergency response facilities.Figure 6.1 represents the locations of the offsite support organizations' EmergencyOperations Centers relative to Vermont Yankee. Descriptions of Vermont Yankee facilitiesand assessment capabilities are presented below.6.1. Emergency Response FacilitiesThe emergency response organization is activated, in part or wholly, dependent upon theoperating crew's recognition of Emergency Action Levels (EALs) which represent aparticular emergency condition. Facility activation may be modified or suspended if thesafety of personnel may be jeopardized by a security event or other event hazardous topersonnel. Classification and subsequent declaration of the appropriate emergencycondition by the Shift Manager transforms the Control Room complex into an emergencycontrol center. Initially, the Control Room crew coordinates all phases of emergencyresponse and corrective action required to restore the plant to a safe condition. TheControl Room staffs attention focuses on regaining plant control as emergency responsepersonnel report and are delegated emergency functions. The following describe eachemergency response facility location.6.1.1. Technical Support CenterA Technical Support Center (TSC) has been established to direct post-accident evaluationand assist in recovery operations of the plant. The TSC is located on the second floor ofthe Administration Building in close proximity to the Control Room and is radiologicallyhabitable to the same degree as the Control Room for postulated accident conditions. Thiscenter is established under the supervision of the Emergency Plant Manager and staffed bymembers of the TSC organization shown in Figure 8.3. A portion of the TSC, as shown inFigure 6.2, is assigned for NRC Incident Response Team members who may bedispatched to the plant. The TSC has the capability to monitor various plant parametersneeded to evaluate accident conditions by accessing the plant process computer and usingthe diagnostic capability that its staff offers. The TSC staff can access more computercapabilities through the support plans listed in Appendix G.Emergency PlanRevision 55Page 28 of 123Entergy Vermont Yankee Upon activation, the TSC provides the main communication link between the plant, theControl Room, the NRC and the Emergency Operations Facility/Recovery Center. Detailsof this communications capability are described in Section 7.0. The plant print files arelocated within the TSC boundary, and contain pending and as-built system and equipmentdrawings, system flow diagrams, isometrics, cable/wiring diagrams, equipment outlinedrawings, UFSAR, Emergency Plan and plant procedures.The TSC is activated by the Emergency Plant Manager when a plant condition exists whichrequires ongoing technical evaluation (i.e., Alert, Site Area or General Emergencyconditions). The TSC may be activated by the Emergency Plant Manager under aNotification of Unusual Event if conditions warrant such an action. The TSC has thecapability to assess radiological conditions. This assessment capability consists ofmonitoring for direct radiation and airborne particulates, and sampling and analysis forairborne 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 thatcontinuous technical assessment is no longer required.6.1.2. The Operations Support CenterThe Operations Support Center (OSC), which is located on the first floor of theAdministration Building, provides a general assembly area for Chemistry, RadiationProtection, Maintenance, Operations, and I&C Personnel (see Figure 6.3). It is staffed withsufficient in-plant personnel required to effect protective and corrective actions in support ofthe emergency situation. An Operations Support Center Manager directs the activities ofthis center. In-plant phone extensions and a page/intercom system provide communicationcapability at the OSC. Emergency equipment listed in Appendix B has been provided withadditional back-up capability provided at the Radiation Protection control point. Ifconditions warrant evacuation of this center, the Emergency Operations Facility/RecoveryCenter assumes OSC functions. The OSC remains active and staffed until terminated bythe 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 PlanRevision 55Page 29 of 123Entergy Vermont Yankee 6.1.3. Emergency Operations Facility/Recovery CenterThe Emergency Operations Facility/Recovery Center (EOF/RC) is located at the VermontYankee Training Center on Old Ferry Road in Brattleboro, Vermont, approximately 8.75miles from the plant site (See Figure 6.1). The EOF has a radiation protection factor of 5and a ventilation system equipped with HEPA filters which can be isolated. TheCommission 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 contactingthe Control Room and plant Security, is available to serve as a staging area for augmentedemergency response staff if the site is under threat of or experiencing hostile action. Theoverall responsibility for the functions performed in the EOF/RC belongs to the EmergencyDirector.The Emergency Director acts as the principal spokesperson for Vermont Yankeeconcerning all issues where an interface with offsite government authorities is required.The Radiological Assessment Coordinator is responsible for continuous evaluation of alllicensee activities related to an emergency having, or potentially having, environmentalradiological consequences. The EOF/RC has sufficient space and design to accommodatethe emergency response organization and responding representatives from governmentand industry who are responsible for limiting offsite consequences (see Figure 6.4). TheEOF/RC provides information needed by federal, state, and local authorities forimplementation of their offsite Emergency Plans, and a centralized meeting location for keyrepresentatives from the agencies.The EOF/RC maintains extensive communications capability with all emergency responsefacilities. Section 7.0 details the extent of this capability. Site access and control, doseassessment, sample analysis, decontamination, and recovery planning activities aredirected from various locations within the EOF/RC. The EOF/RC serves as the primaryevacuation, re-assembly, and off-duty augmentation personnel assembly point. Publicinformation statements concerning the plant emergency status are transmitted from theEOF/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* UFSAREmergency equipment and supplies are maintained at the EOF/RC, including equipmentnecessary to assess radiological habitability. This consists of monitoring for direct radiationand sampling and analysis for airborne radioparticulates and radioiodine. For a list ofEOF/RC emergency equipment, see Appendix B.Emergency PlanRevision 55Page 30 of 123Entergy Vermont Yankee 6.1.4. Deleted6.1.5. Joint Information CenterThe Joint Information Center (JIC) provides a centralized location for conducting joint state,federal and Vermont Yankee emergency news briefings in a manner to avoid hamperingongoing emergency response proceedings. It is expected that state and federal publicinformation personnel will operate from the JIC.The initial designated location of the JIC is the Vermont Yankee Office Building located inBrattleboro, Vermont. If accident conditions (plume trajectory) jeopardize the habitability ofthis 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 pressreleases concerning plant emergency conditions to the media. Prior to their release to themedia, the Emergency Director approves releases.The JIC will be activated upon an emergency classification of an Alert or higher except asnoted below.Activation of the JIC is optional prior to an Alert and is dependent on the escalation of theevent and/or public interest. Prior to the activation of the JIC, the Manager ofCommunications or designee would be coordinating press releases from his/her routineoperations location.6.1.6. Coordination of Radiological DataCentralized coordination of the offsite radiological assessment effort with all organizationsinterested in and/or performing assessments is of importance to ensure that the data andits interpretation are reviewed by all parties. The number and type of organizationsperforming this effort vary with time and following accident declaration and offsitenotification. Initially, plant emergency response personnel are the only organizationperforming this function and they are directed from, and their results evaluated, at theEOF/RC. State authorities join the EOF/RC monitoring and assessment activities. Federalresponse agencies would augment plant and state radiological assessment efforts upontheir arrival.Plant and state monitoring efforts are coordinated at the EOF/RC. All samples arescreened for activity levels in the field. Positive results require additional analysis at theEOF/RC. Analysis is completed in two phases. Initially, the sample is evaluated forradioiodine concentration levels using gamma energy analyses instrumentation. Havingcompleted this analysis, total isotopic determination of activity levels is conducted using aHPGe or equivalent system. The EOF/RC sampling capability is greatly enhanced bycoordinating sample transfer and analysis with the Environmental Laboratory.Emergency PlanRevision 55Page 31 of 123Entergy Vermont Yankee When federal resources respond, a more suitable location than the EOF/RC may beneeded. As stated by the Department of Energy (DOE), the agency charged with the leadof the federal offsite monitoring resources, this effort would be established at some locationin the general vicinity of the plant site that was adequate for the equipment and manpowerdeployed. Arrangements will be made for such a location with DOE and the states when itis required. Wherever this function is located, the basic objective is to assure monitoringefforts from all organizations are coordinated.6.2. Assessment CapabilityThe activation of the Emergency Plan and the continued assessment of accident conditionsrequire extensive monitoring and assessment capabilities. The essential monitoringsystems needed for recognition of abnormal events by the plant operators are incorporatedin the Emergency Action Levels specified in Appendix A. This section briefly describesmonitoring systems as well as other assessment capabilities.6.2.1. Process MonitorsPlant process monitors capability includes indications provided from various monitorslocated throughout the plant systems. Parameters monitored include pressure,temperature, flow, and equipment operating status. Vermont Yankee has also augmentedthese monitoring systems with the instrumentation to detect inadequate core cooling.The manner in which process monitors are used for accident recognition and classificationis given in the detailed Emergency Action Level listings in Appendix A.6.2.2. Radiological MonitorsA number of radiation monitors and monitoring systems are provided on process andeffluent liquid and gaseous lines that serve directly or indirectly as discharge route forradioactive materials. These monitors, which include Control Room readout and alarmfunctions, exist in order that appropriate action can be initiated to limit fuel damage and/orcontain 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, and6. Plant stack radiation monitoring system.Specific details on these monitoring systems such as location, type, etc., are contained inthe plant Updated Final Safety Analysis Report (UFSAR).Emergency PlanRevision 55Page 32 of 123Entergy Vermont Yankee In addition to installed monitoring systems, Vermont Yankee has augmented onsiteradiological assessment capability to include high-range containment and stack radiationmonitoring; improved in-plant iodine detection capability; and arrangements for containmentatmosphere and reactor water samples.6.2.3. Meteorological CapabilityVermont Yankee maintains a 300-foot primary meteorological tower from which thefollowing 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 the33 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 theControl Room and the EOF/RC. These meteorological data are used to calculate offsitedispersion 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 whichthe 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 datafrom the back-up tower are displayed on video graphic recorders located in the ControlRoom.In addition, Vermont Yankee has the capability to access additional meteorologicalinformation through offsite support services. This information can be forwarded to VY doseassessment personnel upon request.Emergency PlanRevision 55Page 33 of 123Entergy Vermont Yankee 6.2.4. Fire Detection DevicesVermont Yankee has an extensive fire detection network which utilizes a combination ofsmoke detectors, thermal detectors, infrared detectors, ultraviolet detectors, and "rate ofrise" detectors, as well as fire system status alarms as a means of providing plant operatorswith complete fire status information. This system is described in the Vermont Yankee FireProtection 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 CO2 extinguishers, standpipe systems,and a continuously available fire brigade.6.2.5. Post-Accident SamplingPost-accident sampling capability provides for emergency sample collection of containmentatmosphere, plant stack halogen and particulate components, and primary coolant.Management implements radiological precautions to limit whole body exposure to5 rem/individual for sampling and analyses conducted using these systems.6.2.6. Facilities and Equipment for Offsite MonitoringStates Emergency Management and/or the system load dispatcher provides reportsconcerning natural occurrences or severe weather conditions that may affect the plantarea. Offsite fire departments of Vernon and Brattleboro notify the plant of any fire whichmight have an impact on the plant. Local Law Enforcement Agencies notify Plant Securityof 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 anoffsite environmental monitoring program. Radiological environmental monitoring stationsfor the site and surrounding area monitor the environment under normal and accidentconditions. Radiological environmental monitoring stations have been established inaccordance with Technical Specification (Technical Requirements Manual) requirements.In addition to the analytical capabilities of the EOF, Vermont Yankee has access to outsideanalytical assistance and laboratory facilities from other non-affected Entergy nuclear sites,State and Federal agencies and other utilities through INPO. This support may include butis not limited to the following:Massachusetts Department of Public Health (MDPH) through the implementation of theNuclear Incident Advisory Team (NIAT) Handbook has laboratory analysis capability at theState Contracted laboratories and those laboratories listed in the New England InterstateRadiation Assistance Plan.Emergency PlanRevision 55Page 34 of 123Entergy Vermont Yankee Other environmental monitoring and analysis support can be requested and arrangedthrough INPO. The INPO Emergency Resources Manual includes the informationnecessary to locate and request specialized equipment and technical assistance in thearea of offsite radiological monitoring. INPO member utilities and suppliers agree to provideassistance as outlined in the INPO Emergency Resources Manual.The above facilities have the capability to perform laboratory analyses of variousenvironmental samples (e.g., terrestrial, marine and air). It is also estimated that theanalytical 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 agenciesin accordance with the Federal Radiological Emergency Response Plan. As discussed inSection 6.1.6, this additional capability is integrated into existing efforts.Emergency PlanRevision 55Page 35 of 123Entergy Vermont Yankee 0 10 20 30 40 50MilesFigure 6.1Location of State and Company Emergency Operating Centersaround Vermont YankeeEmergency PlanRevision 55Page 36 of 123Entergy Vermont Yankee Figure 6.2Technical Support Center LayoutEmergency PlanRevision 55Page 37 of 123Entergy Vermont Yankee CLEANCHEM LAB f/LFigure 6.3Operations Support Center LayoutEmergency PlanRevision 55Page 38 of 123Entergy Vermont Yankee WAREHOUSEHVAC ROOM ) I "NRC ROOM SI STATEASSEMBLYMONITORINGRECOVERY TEAMPLANNING COMMUNICATIONNRC ROOM AREARAD ASSESSMENT AREACHEMISTRYANDSAMPLE ANALYSIS SECURITYLABORATORYw ADMINISTRATIONALTERNATE ALTERNATE ANDFACILITY FACILITY LOG ISTICSFigure 6.4Emergency Operations Facility/Recovery Center LayoutEmergency PlanRevision 55Page 39 of 123Entergy Vermont Yankee 7.0 COMMUNICATIONSThe plant staff has available various means of communication systems for effectivecommunications and coordination with offsite and onsite response organizations and/orteams.A summary of the communication systems is defined in the communication matrix providedin Table 7.1 and outlined below.7.1. InForm Notification SystemThe InForm Notification System is located in the Control Room and the EmergencyOperations Facility. InForm consists of source and destination computers that takeadvantage 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 StatePolice 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 SystemThe Nuclear Alert System (NAS), originating in the Control Room, is a system of dedicatedphone circuits independent of the normal land line phone system. The NAS can be used tonotify the State Police of Vermont, Massachusetts, and New Hampshire of any emergency.This system is a secure (dedicated) communications arrangement and is installed for theprimary 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 StatePolice dispatching points. The activation of the public notification system starts with this24-hour State police link. NAS is tested monthly between the plant and the State Policeagencies.The Nuclear Alert System also links the Control Room, the Emergency Operating Centersand Incident Field Offices of Massachusetts, New Hampshire, and Vermont, and theEmergency Operations Facility/Recovery Center (EOF/RC). This communication systemincorporates 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 inFigure 7.2 (EOF/RC Link).Backup to the NAS phone system is the commercial phone system.Emergency PlanRevision 55Page 40 of 123Entergy Vermont Yankee 7.3. Utility Microwave and Radio SystemsI The Utility Microwave and Radio Systems are located in the Control Room. In the eventthat 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 toprovide updates of plant conditions to NRC Region I.7.4. Mobile UHF Radio SystemThe Mobile UHF Radio System is utilized as a primary means of communications for offsitemonitoring teams and security personnel; it is the alternate means of communicationsbetween the EOF/RC, the Control Room, TSC, and onsite response teams. The Systemconsists of 100-watt UHF repeaters with high gain antennas. These repeaters areactivated by any of the six base radio stations located in the Control Room, SecondaryAlarm System (SAS), TSC, Security Gate 1 and CAS, and the EOF/RC. Also, the portableunits activate the repeater. In the event the repeater fails, a "talk around" feature allowscontinued communications between portable units. This system is tested daily throughoperational use of the system.Security also has the capability to contact via radio the Windham County Sheriff Dispatcherand any Vermont State Police Patrol Vehicle(s) located in close proximity to the plant.7.5. Plant Intercom SystemThe Intercom System (Gai-Tronics) is located in many areas throughout the plant, includingthe Control Room, Technical Support Center, Operations Support Center and SecurityGates 1 and 2. This system consists of four channels and is utilized as a paging systemduring normal operations. During emergency situations, the system is used as the primarymeans for: (1) notifying plant personnel of the emergency, (2) coordinating the activities ofonsite response teams with the Technical Support Center; (3) coordinating activitiesbetween Control Room and the Technical Support Center; (4) calling for any missing orunaccounted for personnel that may be in the plant; and (5) communicating between theplant emergency response facilities. This system is in continuous daily use.7.6. NRC Telephone SystemThe NRC has utilized the Federal Telecommunications System (FTS) telephone networkfor its emergency telecommunications system. The FTS system provides a separate(public cannot access) government telephone network which avoid potential publictelephone blockage which may occur in the event of a major emergency.The Emergency Notification System (ENS) utilizes an FTS line which exists between theNRC Operations Office in Rockville, Maryland and the Control Room, with extensions in theCommunications Room and the NRC Room (NRC Resident Inspector's Office) of theTechnical Support Center. This line is tested daily by the NRC and has a 24-hour manningcapability at both organizations.Emergency PlanRevision 55Page 41 of 123Entergy Vermont Yankee The Emergency Notification System (ENS) also utilizes a separate FTS line between theNRC Operations Office in Rockville, Maryland and the EOF/RC.The Health Physics Network (HPN) which utilizes separate FTS lines from the TSC andEOF/RC, allows Vermont Yankee to transmit health physics and environmental informationto the NRC through the Operations Center in Rockville, Maryland in a radiological event.7.7. Commercial Telephone SystemThe commercial telephone system is used as a primary and alternate means ofcommunications for notification and coordination. For conditions involving telephonecompany equipment blockage in the local area, alternate external telephone linearrangements have been made available to the plant.7.8. Emergency Power Supply for CommunicationsCurrently there are several telephone and other emergency communication channels(Gai-Tronics, radio network, and microwave) located within the plant that are connected toan emergency or redundant power supply. All emergency communications (including allphones) 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 willautomatically activate if power is lost to the internal telephone system.7.9. Facsimile TransmissionHigh speed, quality facsimile equipment is located at the Technical Support Center (TSC),Operations Support Center (OSC), Emergency Operations/Recovery Center, JointInformation Center (JIC), and each respective state's Emergency Operation Center (EOC).This is used to transmit pertinent data and information concerning the emergency amongthese facilities.Emergency PlanRevision 55Page 42 of 123Entergy Vermont Yankee 7.10. DeletedEmergency PlanRevision 55Page 43 of 123Entergy Vermont Yankee TABLE 7.1VERMONT YANKEE EMERGENCY COMMUNICATIONS MATRIXCALLING FROTSC OSCCALLING TOTechnical Support Center (TSC)Operations Support Center (OSC)Emergency Operations Facility (EOF)Joint Information Center (JIC)Offsite and Site Boundary MonitorsNuclear Regulatory CommissionState Police (VT, NH, MA)State EOCs (VT, NH, MA)Vermont Yankee Plant SecurityVermont Yankee EmergencyResponse PersonnelCR1,4,5,71,71,2,411,41,51,2,111,2,9,111,4,71,81,71,4,101,101,41,5,611111111MEOF1,101,41,5,61,2,111,2,9,10,111,4,71,8JIC1111,4,7 1,71,81,81,8KEY1234567891011Commercial Telephone SystemNuclear Alert SystemUtility MicrowaveMobile UHF Radio SystemEmergency Notification SystemHealth Physics NetworkGai-TronicsPersonnel Pager SystemSouthwest Fire RadioFacsimile TransmissionInFormEmergency PlanRevision 55Page 44 of 123Entergy Vermont Yankee NOTES:1. SEE STATE RESPONSE PLAN FORCOMMUNICATION CHANNELSBETWEEN STATE POLICE ANDSTATE AGENCIES AND LOCALS.2. SEE STATE RESPONSE PLAN FORLOCALS AND OTHER STATEAGENCIES TO BE NOTIFIED.Figure 7.1Plant to State Notification ChannelsEmergency PlanRevision 55Page 45 of 123Entergy Vermont Yankee NOTE:1. SEE STATE RESPONSE PLANS FORCOMMUNICATION CHANNELS BETWEENSTATE EOC'S AND FWD EOC'S.2. SEE STATE RESPONSE PLAN FORLOCALS AND OTHER STATE AGENCIESTO BE NOTIFIED........VERMONT l, VERMONT PRIMARY} ! CENTER .. .(DUMMERSTON):-up.I* I1 MASSACHUSETTS MASSACHUSETTS'....- EMERGENCY OPERTIO NOTE 1 REGION III EOC3 UNLISTED TELE. NOS.011-EA STATE..................... ...OlILEGEND:O PRIMARY0 SECONDARY( TERTIARY-LOCAL PHONEI II NEW HAMPSHIREEMERGENCY OPERATIONS* CENTER*..............NUCLEAR ALERT SYSTEM....... INFORMFigure 7.2Coordination Channels with StatesEmergency PlanRevision 55Page 46 of 123Entergy Vermont Yankee 8.0 ORGANIZATIONThis section describes how the normal plant and engineering support organizationtransform into an emergency response organization to effectively deal with any incident atVermont Yankee.8.1. Normal Plant OrganizationVermont Yankee's normal operation and management organization consist of the onsitefacility organization supported by the engineering and management organizations locatedoffsite. The relationship and content of these onsite and offsite organizations are specifiedin the plant Technical Specifications, Technical Requirements Manual or Entergy QualityAssurance 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. Theresponsibility for determining the status of the plant in an emergency is assigned to theShift Manager or, in his absence from the Control Room, to the CFH who has the authorityand responsibility to immediately initiate any emergency actions, including emergencyclassification and notification. Additional personnel are available on an on-call basis torespond to plant emergencies. Corrective action and repair, as outlined in Table 8.4, isperformed by Operations staff on-shift until supplemented by additional ERO staff.8.2. Emergency Response OrganizationThe Vermont Yankee emergency response organization is activated in part or in whole,depending upon the condition classification determined by the normal plant operations crewin the Control Room. Vermont Yankee's emergency response organization is divided intoonsite and offsite elements. The Vermont Yankee Emergency Management Organizationis shown in Figure 8.2. Staffing for the onsite emergency response facilities is shown inFigure 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 (EmergencyOperations Facility/Recovery Center). All or portions of these organizations are activateddepending upon the emergency classification.Elements of the emergency response plan are activated subsequent to an emergencydeclaration by the Shift Manager; designated company personnel are notified and willreport to designated locations. The emergency response action of the personnel alreadypresent are performed on a priority basis depending on the emergency conditions and theimmediate need which those conditions dictate as determined by the on-shift operationscrew. The specific priorities facing the emergency response forces in the various locationscannot be pre-established. They would be specific to the nature of the emergency andvariable with time as it proceeds.Emergency PlanRevision 55Page 47 of 123Entergy Vermont Yankee Plans and procedures have been put into place to ensure the timely activation ofemergency response facilities. Although the response time will vary due to factors such asweather and traffic conditions, a goal of sixty (60) minutes for activation has beenestablished for onsite emergency facilities including the EOF.For this reason, the coordinators and managers in the emergency response facilities arecharged with the responsibility of determining the priority of response functions wheninitially activated and assembled, and ensuring that the needed functions be performed onthe basis of the priority determination. This process of prioritizing needs and addressingthem accordingly is specified in the Emergency Plan's implementing procedures.In emergency situations, the Shift Manager, Emergency Plant Manager, or OSC Managercan authorize actions, without following the complete work order process, if these actionsprevent the following:* Loss of important equipment, or* Personnel injury.The Emergency Plant Manager and OSC Manager are responsible for updating the ShiftManager when plant systems will be taken out and returned to service.The titles of positions in the Vermont Yankee Emergency Management Organization areshown in Figure 8.2.Emergency PlanRevision 55Page 48 of 123Entergy Vermont Yankee 8.2.1. Emergency DirectorThe Emergency Director is a manager of Vermont Yankee who has the requisite authority,management ability, technical knowledge, and staff to manage the site emergency andrecovery organization. The Emergency Director is responsible for the direction of the totalemergency 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 responseactions necessary for control of the accident and protection of emergencypersonnel 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 andtransmittal of offsite protective action recommendations; (non-delegable)5. Manage all emergency elements required to restore the plant to a safecondition;6. Coordinate accident information and assume the role of utility liaison withoffsite 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 NRCrepresentatives;9. Approve public information releases; and10. Perform or direct the emergency response organization manpower planningeffort to assure the availability of sufficient staff to implement all necessaryfunctions, should the emergency response efforts be over a prolonged period.The Emergency Director or designated alternate is notified of all emergency conditionsoccurring 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 emergencyresponse organizations throughout the emergency condition and until the recoveryactivities have been terminated.Emergency PlanRevision 55Page 49 of 123Entergy Vermont Yankee 8.2.2. Emergency Plant ManagerThe Emergency Plant Manager has direct responsibility for the conduct of operations at theplant. During an emergency situation, the Emergency Plant Manager is responsible for theoverall supervision and coordination of the onsite emergency response activities anddirects the activities of the Technical Support Center until the accident is terminated. TheEmergency 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 theinstallation of short-term modifications, and define emergency operationprocedures during the modification period;4. Analyze problems in the area of system operations, determine emergencyprocedures related to system operations and establish shift operationssupport, if applicable;5. Develop guidance for plant shift operations concerning plant protection;6. Oversee the accumulation, retention, retrieval and transmission of vital plantparameters required to analyze the accident progression and subsequenttermination;7. Provide assistance to the Shift Manager or Emergency Director on theescalation and de-escalation of the emergency classification as conditionswarrant;8. Initially direct the activities of onsite and offsite teams until EOF becomesoperational.A qualified manager assumes the role of Emergency Plant Manager under all emergencyconditions. To assist the Emergency Plant Manager, the TSC is staffed by representativesfrom the following departments as depicted in Figure 8.3:* Operations* Maintenance* Engineering* Chemistry* Radiation Protection* Security (stationed at the off site command post)Emergency PlanRevision 55Page 50 of 123Entergy Vermont Yankee 8.2.3. Shift ManagerThe Shift Manager is the Duty Shift Manager. The alternate is the Control RoomSupervisor of the assigned operating crew in the Control Room at the time of theemergency. The Shift Manager is responsible for initiating emergency actions to limit theconsequences of the event and bring it under control. The immediate responsibilities of theShift Manager include performing or delegating performance of the following:1. Recognition of emergency conditions by observation of characteristicemergency action levels (EALs);2. Classifications of accident conditions in accordance with the emergencyclassification system;3. Implementation of emergency operating procedures applicable to the eventcondition;4. Initiation of the appropriate emergency plan implementing procedure;5. Prompt notification of Vermont, New Hampshire and Massachusetts StatePolice indicating the event classification;6. Notification of the NRC indicating the event classification;7. Initial offsite dose assessment activities; and8. Offsite protective action recommendation and initial transmittal to Stateofficials.Subsequent responsibilities undertaken by the Shift Manager include:1. Notification of appropriate plant and company management personnel of theemergency conditions;2. Direction and coordination of all initial emergency response efforts until thesupport elements of the emergency response organization are activated; and3. Limiting the consequences of the accident and restoring the plant to a safecondition.As part of the plant notification system, the Shift Manager has selected plant managementand department head personnel notified using a radio paging/telephone system. This is themechanism for mobilizing plant support personnel and activating the remainder of theonsite emergency response organization.8.2.4. DeletedEmergency PlanRevision 55Page 51 of 123Entergy Vermont Yankee 8.2.5. Operations Support Center ManagerA member of the plant staff is assigned to coordinate the functions of the OperationsSupport Center. The responsibilities of the Operations Support Center Manager include:1. Provide system valve alignment and equipment operation support to the ShiftManager;2. Assist in coordinating recovery efforts as requested by the Emergency PlantManager;3. Provide Radiation Protection and Chemistry support for the in-plantemergency radiation protection and sampling activities;4. Assign available personnel to the following emergency team function asnecessary:a. Site Boundary Survey Monitoring Teamb. Offsite Monitoring Teamsc. Repair and Corrective Action/Rescue Team5. Brief OSC teams on in-plant radiation protection controls.The OSC Manager directs the OSC and maintains this facility until the termination of theevent. The OSC Manager establishes a base of operations in the OSC, but may find itnecessary to go to the TSC from time to time.Emergency PlanRevision 55Page 52 of 123Entergy Vermont Yankee 8.2.6. Radiological Assessment CoordinatorDuring emergency conditions, the Radiological Assessment Coordinator is responsible forthe development of plans and procedures to assess and control radiological exposure insupport of and consistent with the emergency response and recovery organizationobjectives. The primary emergency responsibilities of the Radiological AssessmentCoordinator include:1. Assess the onsite and offsite radiological conditions associated with anyaccidental releases.2. Evaluate offsite doses based on radiation monitoring performed by monitoringpersonnel;3. Provide support to the TSC to ensure onsite protective actionrecommendations (i.e., decontamination procedures, protective clothing, etc.)are being considered and carried out;4. Continuously update the Emergency Director concerning dose assessmentresults and recommend offsite radiological protective actions to theEmergency Director;5. Recommend administrative limits for radiological exposure control ofemergency workers in keeping with those specified in Table 10.2 andmaintain the necessary records; and6. Review plans and schedules of tasks with appropriate managers andcoordinator of the recovery organization concentrating on radiation protectionprocedures.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 withoffsite response and assistance organizations.The immediate priority of the Radiological Assessment Coordinator and staff is radiologicalanalysis of air samples taken by offsite monitoring teams. For the long-term, additionalduties include the analysis of contamination levels in area vegetables, fruits, milk, or water,and soil samples. To accomplish this long-term requirement, the Radiological AssessmentCoordinator works closely with the services provided by support organizations (e.g.,Environmental Lab).Emergency PlanRevision 55Page 53 of 123Entergy Vermont Yankee 8.2.7. Administration and Logistics CoordinatorThe 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 managementdisciplines;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 emergencyresponse centers;5. Maintain adequate contractual communication services for the siteemergency organization; and6. Initially be responsible for procurement using established emergencyprocurement procedures.NOTE: Subsequently, normal Purchasing Department operations and procedures areused as directed by the Emergency Director.The Administration and Logistics Coordinator establishes operations at the EOF/RC andassists the Emergency Director, as requested.8.2.8. Security CoordinatorThe Security Coordinator directs the security personnel in maintaining required security insupport of the emergency operations. The functional responsibilities of the SecurityCoordinator include:1. Establish security around the plant site and/or any other areas identified bythe 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; and5. Maintain overall plant security in accordance with the Plant Security Plan.The Security Coordinator interfaces with the Emergency Plant Manager for in-plant securityactions. The Security Coordinator is stationed at the off-site command post.Emergency PlanRevision 55Page 54 of 123Entergy Vermont Yankee 8.2.9.Company SpokespersonThe Company Spokesperson is authorized to provide the public with informationconcerning the emergency. The emergency responsibilities of the Company Spokespersoninclude:1. Establish a Joint Information Center when necessary;2. Coordinate information at the Joint Information Center with counterparts fromlocal, state and federal agencies and with other companies involved with theemergency; and3. Present terminology concerning accident conditions in an easily understoodand 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 theCompany Spokesperson.8.2.10. Decision MakerDuring implementation of Severe Accident Management (SAM), the OperationsCoordinator in the TSC will assume the role of Decision Maker as defined in plantprocedures.8.2.11. Engineering Support GroupThe Engineering Support Group is an engineering group established to provide emergencysupport 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 variousonsite engineering groups. In addition, the engineering support group may access offsiteengineering resources through the support programs listed in Appendix G. This groupresides in the Technical Support Center, and communicates with offsite technical supportpersonnel. This group has access to the technical expertise to provide a variety ofemergency functions, such as engineering analyses and plant system assessment insupport of recovery efforts.Emergency PlanRevision 55Page 55 of 123Entergy Vermont Yankee 8.3. Recovery OrganizationThe emergency measures presented in this plan are actions designated to mitigate theconsequences of the accident in a manner that affords the maximum protection to thepublic. Planning for the recovery mode of operations involves the development of generalprinciples 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 thefoundation for such a recovery organization.The Emergency Director directs the recovery organization. As indicated in Figures 8.1through 8.5, the organization relies on more than plant staff and/or resources to restore theplant to normal conditions. The expertise provided through the support plans is available toaid with the necessary corrective actions required to control and/or restore normal plantstatus. Various State and Federal support groups augment the recovery organization. Thefollowing is a brief summary of the recovery organization's responsibilities:1. Maintain comprehensive radiological surveillance of the plant to assurecontinuous 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 theemergency organization in reducing public hazard and/or plant damage;7. Provide offsite authorities with status report as to the operations capabilitiesof the plant;8. Provide assistance to recovery actions undertaken by state/local authorities, ifrequested; and9. 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 therecovery organization. The actions taken by this organization concerning termination of theemergency proceeds in accordance with a recovery plan developed specifically for theaccident conditions.Emergency PlanRevision 55Page 56 of 123Entergy Vermont Yankee 8.4. Extensions of Vermont Yankee Emergency Organization8.4.1. Local ServiceArrangements have been made for the extension of the emergency organization capabilityfor handling emergencies to provide for:1. Transportation of injured personnel using an ambulance service;2. Treatment of radioactively contaminated and injured personnel at a localsupport hospital (Brattleboro Memorial and Baystate Franklin Medical Center)and other regional medical facilities as specified in the local support hospitalplans; and3. Fire support services by the Vernon and Brattleboro Fire Departments andthe Tri-State and Southwestern Fire Mutual Aid Networks.4. Law enforcement support services provided by local, county, state, andfederal law enforcement authorities as appropriate and response capabilitiesare documented in the letters of agreement maintained by Security.Evidence of agreements with participating local services is found in Appendix E, VermontYankee Fire Protection, Appendix R Program, and the Annual Law Enforcement Letters ofAgreement (Safeguards Information) maintained by Security.8.4.2. Federal Government SupportResources of federal agencies appropriate to an emergency condition are made availablein accordance with the National Response Framework. This plan and the resources behindit are activated through the plant notification of the NRC. Many resources are madeavailable, as deemed necessary by the emergency condition, including a major effort underthe leadership of the Department of Energy applied to the area of offsite radiological impactassessment. This effort can involve manpower and equipment for extensive plumemeasurement, including aerial monitoring and tracking, and sampling and analysis ofingestion pathway media.Emergency PlanRevision 55Page 57 of 123Entergy Vermont Yankee 8.4.3. Additional SupportDependent upon the emergency condition and response needs, the Vermont Yankeeemergency organization can be augmented by manpower and equipment support from theremainder of the Entergy Nuclear organization. This support capability is outlined in theCorporate Support procedure as referenced in Appendix G.Should response support beyond this level be required, additional support from othernuclear industry organizations can be requested through interface with the Institute ofNuclear Power Operations (INPO). Informational notifications are provided to thisorganization whenever emergency conditions escalate to an Alert or greater emergencycondition. The decision to request additional industry support is a responsibility of theEmergency Director. All industry support organizations reporting to the site are assignedby emergency management, located in the EOF/RC, who specifies their authorities,responsibilities and any limits on their actions. All responding parties are required toadhere to existing plant procedures while completing their assignments.8.5. Coordination with State Government AuthoritiesBecause of the location of the Vermont Yankee Plant, the planning and/or actionresponsibilities at the state level involves coordination of three states; Vermont, NewHampshire, and Massachusetts. Section 7.0 describes the extensive communicationsnetwork between Vermont Yankee and these states as a means of promptly notifyingappropriate authorities under accident conditions. Table 8.3 provides a summary ofemergency plan areas and the associated plant, state and local responsibilities.The Shift Manager initiates the coordination effort by notifying Vermont, New Hampshireand Massachusetts State Police, providing them with an established message format thatdescribes the accident status. Based on the emergency class, the State emergencyresponse personnel are alerted and/or mobilized. To ensure effective coordination ofoffsite emergency response actions, representatives of each state are assigned to report tothe EOF/RC for first-hand emergency information and assessment. They are providedspace in the EOF/RC as shown in Figure 6.4. The Emergency Director or designee issuesperiodic accident reports to the responding State Representative. Each staterepresentative is responsible for transferring the content of these status reports to theirrespective State Emergency Operating Center (EOC). If additional technical expertise isrequired by state authorities at the state Emergency Operating Centers (EOCs), theEmergency Director can authorize dispatching of technical support staff to assist them incomprehension of any emergency communications.Based upon the accident assessment, protective measures are recommended andimplemented by each state according to actions and decisions prescribed by each state'sEmergency Plan. The Vermont Health Department will notify the New York StateDepartment of Public Health concerning all ingestion pathway considerations. Additionalstate support can be called upon from any or all other New England states through theagreement specified in the New England Compact on Radiological Health Protection.Emergency PlanRevision 55Page 58 of 123Entergy Vermont Yankee TABLE 8.3(Page 1 of 3)A SUMMARY OF OFFSITE COORDINATIONEMERGENCY PLAN FUNCTIONProtective Action DecisionMakingPLANT RESPONSIBILITYThe Shift Manager issues the initialprotective action recommendation.STATE RESPONSIBILITYState Police receive the initialnotification whereupon they activatethe State fan-out notification process.LOCAL RESPONSIBILITYThe State Directors ofEmergency ManagementAgencies will notify either thelocal emergency managementdirectors or the selectmen ofthe recommended action andadvise.After the Emergency Director (ED)assumes overall responsibility, theED will issue protective actionrecommendations to the appropriateState authorities (non-delegable).In the State of Vermont, the Directorof the Vermont EmergencyManagement Agency and the Directorof the Division of Occupational Healthand Radiological Health and Safetywould activate.In the Commonwealth ofMassachusetts, the Director of theMassachusetts EmergencyManagement Agency and the Directorof the Radiation Control Branch of theMassachusetts Department of Publichealth would activate.In the State of New Hampshire, theDirector of the New Hampshire Officeof Emergency Management and theDivision of Public Health Serviceswould activate.Emergency PlanRevision 55Page 59 of 123Entergy Vermont Yankee TABLE 8.3 (Continued)(Page 2 of 3)A SUMMARY OF OFFSITE COORDINATIONEMERGENCY PLAN FUNCTIONProtective Action DecisionMaking (continued)PLANT RESPONSIBILITYSTATE RESPONSIBILITYEach State Health representativewould call or report to the plant for thefollow-up protective actionrecommendation issued by theEmergency Director.Each State Health representative willreview all factors and issue a finalrecommendation to the Directors ofState Emergency managementAgencies, who, in turn, will initiateresponse actions to implement thisrecommendation.A coordination between the States willdecide the time to implement theproposed actions, including activatingthe public alert and instructionalmethods (e.g., siren activation/NOAmessage, etc.)Each State Health representative atthe EOF/RC will request monitoringupdates from the Lead Offsite Liaison.In the State of Vermont, the Director ofthe Division of Occupational &Radiological Health & Safety willcommand this function at the StateEOC.LOCAL RESPONSIBILITYCoordination of Radiological DataThe Radiological AssessmentCoordinator is responsible forcompiling offsite monitoring resultsand for ensuring an effectivedeployment of monitoring personnelas well as coordinating informationtransfer.Local communities rely onState capability for radiologicalevaluation.Emergency PlanRevision 55Page 60 of 123Entergy Vermont Yankee TABLE 8.3 (Continued)(Page 3 of 3)A SUMMARY OF OFFSITE COORDINATIONEMERGENCY PLAN FUNCTIONCoordination of Radiological Data(continued)PLANT RESPONSIBILITYThe Emergency Director will advisethe State response personnel ofresults.Plant Access ControlEvacuation ProcessPublic Information ReleaseThe Security Coordinatorcoordinates plant site security andoffsite law enforcement support asnecessary.Shift Manager will sound evacuationalarm under Site Area or GeneralEmergencies.OSC Manager will direct personnelto monitor all plant evacuees.The Emergency Director issues finalapproval prior to release.The Technical Advisor at theEOF/RC relays accident statusreports to the Joint InformationCenter.The Company Spokespersonreleases the information to themedia.STATE RESPONSIBILITYIn the Commonwealth ofMassachusetts, the Director of theRadiation Control Branch of theMassachusetts Department of PublicHealth will command this function atthe State EOC.In the State of New Hampshire, theDirector of the Division of PublicHealth Services will command thisfunction at the State EOC.State Police would respond asdirected by the Directors of theEmergency Management Agencies.State Emergency managementAgencies will coordinate the activationof the Public Notification System.Health and Human Services or RedCross representative will coordinatethe establishment of ReceptionCenters.State press personnel report to theJoint Information Center.State press personnel coordinatereleases with the CompanySpokesperson.LOCAL RESPONSIBILITYLocal police would assist asdirected by the State Police.Media inquiries are referred tothe Joint Information Center.Emergency PlanRevision 55Page 61 of 123Entergy Vermont Yankee Table 8.4(Page 1 of 2)MINIMUM STAFFING REQUIREMENTS FOR THE ENVY EROFUNCTIONAL MAJOR TASKS ENVY POSITION TITLE1 RESPONSEAREA TIMEPlant Operations & Shift Manager (1) On ShiftAssessment of Certified Fuel Handler (CFH) (1) On ShiftOperational AspectsNon-Certified Operator (NCO) (3) On ShiftEmergency Direction Shift Manager (1"*) On Shift& Control(EmergencyCoordinator)***Notification / Notify Licensee, State CFH On ShiftCommunication local and federal Offsite Comm/ENS Comm (1) 3 30 min.personnel & maintain Offsite Comm/ENS Comm (2) 3 60 min.communicationRadiological Emergency Operations EOF Emergency Director (1) 60 min.Accident Facility (EOF) Director Shift Mgr/CFH On ShiftAssessment and Offsite Dose assessment RP Staff (1)4 30 min.Support ofOperational 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 ShiftRP staff (1) 30 min.RP staff (1) 60 min.Chemistry / Chem staff (1) 60 min.RadiochemistryPlant System Shift Technical Advisor Positions not needed in a PermanentlyEngineering Core/Thermal hydraulics Defueled ConditionElectrical TSC Manager / TSC Engineering staff (1) 60 min.Mechanical TSC Manager / TSC Engineering staff (1) 60 min.Repair & Corrective Mechanical Maintenance NCO(I**) On ShiftActions Mechanical Maintenance Maintenance (1) 60 min.Rad Waste operator NCO 60 min.Electrical Maintenance / NCO(1 **) On ShiftInstrumentation & Control Maintenance (1) 30 min.Technician Maintenance (1) 60 min.Instrumentation & Control Maintenance (1) 30 min.Technician IEmergency PlanRevision 55Page 62 of 123Entergy Vermont Yankee Table 8.4 (Continued)(Page 2 of 2)MINIMUM STAFFING REQUIREMENTS FOR THE ENVY EROFUNCTIONAL MAJOR TASKS ENVY POSITION TITLE1 RESPONSEAREA TIMEProtective Actions Radiation protection, NCO(2**) 2 On Shift(In Plant) access control, HP RP (2) 30 mincoverage for repair, RP (2) 60 mincorrective actions, search& rescue, first aid &firefighting, personnelmonitoring, dosimetryFire Fighting Fire brigade* (5**) 1 On ShiftLocal 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 INOTE: 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 functionsOverall 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 supportcenter or control room.NOTES1. AP 0894 specifies minimum shift staffing requirements. FB requires 5 persons per TRM and theVermont Yankee Nuclear Power Station Analysis of Proposed Post-Shutdown On-Shift Staffing.The staffing analysis was evaluated to reflect VY's permanently shutdown and defueledconditions, including the on-shift staff composition and revised accident analyses. Titles of ENVYERO positions are shown.2. All NCOs use digital dosimeters with features for dose rate and total dose monitoring. NCOs aretrained to self-monitor in an emergency.3. ENVY has designated ERO members who staff positions required to meet minimum staffing toactivate the TSC, OSC and EOF. The minimum staff positions required to activate the TSC andEOF are shown in E Plan Figures 8.3 and 8.5. The OSC Manager is the only position required toactivate and staff the OSC. All ERO personnel are expected to respond when notified by theemergency 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 PlanRevision 55Page 63 of 123Entergy Vermont Yankee I IL -iFire Brigade** May be provided by shift personnel assigned otherfunctions. Fire Brigade positions are staffed inaccordance with Technical Requirements Manualand administrative procedures.Note,Corrective action repair is performed byOperations Staff on-shift until supplementedby the emergency response organization.[xJ = Number of IndividualsFigure 8.1Defueled On-shift Emergency Organization.Emergency PlanRevision 55Page 64 of 123Entergy Vermont Yankee Figure 8.2VY Defueled Emergency Management OrganizationEmergency PlanRevision 55Page 65 of 123Entergy Vermont Yankee

.required for activationFigure 8.3Defueled Technical Support Center Emergency OrganizationEmergency PlanRevision 55Page 66 of 123Entergy Vermont Yankee Dose Assessment Team

• required for activationFigure 8.5Defueled Emergency Operations Facility OrganizationEmergency PlanRevision 55Page 67 of 123Entergy Vermont Yankee

.required for activationFigure 8.7Defueled Joint Information Center OrganizationEmergency PlanRevision 55Page 68 of 123Entergy Vermont Yankee 9.0 EMERGENCY RESPONSE9.1. Emergency Condition Recognition and ClassificationVermont Yankee maintains the capability to assess, classify, and declare an emergencycondition within 15 minutes after the availability of indications to plant operators that anemergency action level has been exceeded and promptly declares the emergencycondition as soon as possible following identification of the appropriate emergencyclassification level.Section 5.0 presents the emergency classification system used for categorizing the widespectrum of possible emergency conditions into one of four emergency classes. Theprocess of condition recognition, immediate response to correct the condition, eventclassification, and initiation of the appropriate emergency implementing procedures are allcritical responsibilities of the Shift Manager and the operations crew. This has beenrecognized in the design of both the emergency operating and emergency implementingprocedures. The step between condition recognition and classification is handled as aprocedural transition from the emergency operating procedure applicable to the event, to aspecific emergency implementing procedure.The specific transition procedure contains the listing of conditions that represents each ofthe four emergency categories and the detailed Emergency Action Levels (EALs) that allowthe Shift Manager to determine the emergency classification. Once the emergency isclassified, the applicable emergency implementing procedure is initiated. This is the triggerfor the activation of the plant emergency response organization and the notification ofoffsite authorities for the activation of their emergency response. The activation of the plantemergency response organization brings to the assistance of the operations shift personnelall the various support elements described in this plan. How specific support elements areimplemented, are detailed in the emergency implementing procedures. See Appendix Gfor a listing of these procedures.9.2. Activation of the Emergency OrganizationThe Shift Manager activates the emergency organization if plant conditions reachpredetermined Emergency Action Levels (Appendix A). Depending upon the specific actionlevels attained, the Shift Manager declares one of the following: Notification of UnusualEvent, Alert, Site Area Emergency, or General Emergency.Emergency PlanRevision 55Page 69 of 123Entergy Vermont Yankee 9.2.1. Notification of Unusual Event ResponseAppendix A defines the conditions that require the declaration of a Notification of UnusualEvent. Emergencies defined within this classification demand the mobilization of specificemergency response members and the initiation of precautionary and/or corrective actionswhich mitigate the consequences of the event. A Notification of Unusual Event does notactivate the entire emergency response organization, but may require augmentation ofon-shift resources to deal with the event. Offsite emergency organizations are notified forinformational purposes, and aid from offsite fire, medical, and security organizations maybe required depending on the nature of the event.The response required as a result of this declaration of a Notification of Unusual Eventvaries according to the specified event, but a general summary of actions taken isdescribed below:1. The emergency condition is recognized and classified by the Shift Managerwho instructs Control Room personnel to announce over the plant pagesystem the emergency classification;2. The on-duty operations shift and selected plant personnel respond asdirected by the Shift Manager;3. Appropriate plant staff are directed to assume various emergency functions;4. Control Room personnel notify the New Hampshire, Massachusetts andVermont State Police. The State Police notify the appropriate stateauthorities;5. The NRC is notified;6. Other support is requested as necessary;7. The Emergency Call-in Method is implemented as shown in the notificationplan (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 personneluntil overall responsibility is assumed by the Emergency Director;10. If necessary, appropriate emergency medical, fire department, or lawenforcement agencies are notified and requested to respond;11. The TSC may be activated at the discretion of the Emergency Plant Manager;Emergency PlanRevision 55Page 70 of 123Entergy Vermont Yankee

12. The public information representative is notified and handles publicinformation associated with the event; and13. The Shift Manager terminates the Notification of Unusual Event status andcloses out the event with a verbal summary to offsite authorities or escalatesto higher level emergency classification.9.2.1.1. Unusual Event (Terminated) ResponseIf a condition that warrants a Notification of Unusual Event declaration has occurred, andwas immediately rectified such that the condition no longer existed by the time ofdeclaration, this Notification of Unusual Event classification is referred to as an UnusualEvent (Terminated).The event or condition did not affect personnel onsite or the public offsite, or result inradioactive releases requiring offsite monitoring.The response to this declaration of an Unusual Event (Terminated) is not ascomprehensive as that for a Notification of Unusual Event. All the same notifications for aNotification of Unusual Event are made, and emergency response personnel reporting tothe plant are based on specific requests of the SM.9.2.2. Alert ResponseAn Alert requires actions to: 1) assure that sufficient emergency response personnel aremobilized to respond to the accident conditions at the site; and 2) that offsite emergencyorganizations are readily available to respond to the situation. Prompt notification is madeto state officials and follow-up information is provided as needed to offsite emergencyorganizations. Unassigned personnel are evacuated from the site. In an Alert, the stepslisted in the Notification of Unusual Event Response section (except for the terminationprocess) and the following are performed:1. The Alert emergency notification and response, as shown in Figure 9.1 anddescribed in Table 9.1 are implemented;2. The Technical Support Center, Operations Support Center, the EmergencyOperations Facility/Recovery Center, and the Joint Information Center areactivated by personnel as shown in Table 9.1;3. If sufficient personnel are not available onsite, off-duty personnel are called inas specified in the emergency implementing procedures;4. The Emergency Plant Manager reports to the Technical Support Center anddirects in-plant emergency operations;5. The Emergency Director establishes operations in the EOF/RC;Emergency PlanRevision 55Page 71 of 123Entergy Vermont Yankee

6. The Vermont, Massachusetts, and New Hampshire state emergencyresponse personnel, having been notified through the state fan-out process,respond in accordance with their respective Radiological EmergencyResponse Plans;7. The Emergency Director reports to the EOF/RC and assumes totalresponsibility for overall emergency response actions and recovery;8. The Joint Information Center is established and timely public information ispresented through coordination between the Emergency Director and offsiteauthorities;9. Offsite authorities are provided periodic meteorological assessments and, ifreleases are occurring, projected dose estimates. (Note: If radiologicalreleases are occurring, monitoring teams are dispatched.); and10. The Emergency Director reaches agreement with offsite authoritiesconcerning de-escalation or termination of the event, and closes out the eventby verbal summary to offsite authorities. If an event is a reportableoccurrence, a written summary is issued to these authorities in an appropriatetime frame through distribution by the Emergency Plan Manager.9.2.3. Site Area Emergency ResponseIn a Site Area Emergency, the steps listed in the Alert Response section and the followingare performed:1. All Vermont Yankee emergency response personnel are notified and reportas described in Table 9.1;2. The Engineering Support Group works in concert with the TSC to resolveengineering support and assist in coordinating equipment resources;3. State emergency response personnel are dispatched to the EOF/RC asstate/local emergency response organizations become fully mobilized;4. Plant conditions are continually assessed and protective actionrecommendations to offsite authorities are made on the basis of thisassessment and/or actual or projected offsite radiological impacts;5. Termination actions are initiated in the same manner as that identified for anAlert. A closeout, de-escalation to recovery phase, or escalation of theemergency classification is made in coordination with offsite authorities.Emergency PlanRevision 55Page 72 of 123Entergy Vermont Yankee 9.2.4. General Emergency ResponseAll Emergency Centers are activated and all available resources are called upon in theevent of a General Emergency. The plant promptly notifies offsite authorities and initiatesall emergency response organization capabilities.Offsite authorities fully activate their emergency response and implement appropriateprotective measures based on meteorological information, actual or projected radiologicaldose conditions and/or conditions. The Emergency Director and the entire emergencyresponse organization assemble plant status parameters and continually advise offsiteauthorities of the type of public protective action most appropriate to the situation based onplant conditions and offsite dose projections. This includes whether to shelter or evacuatethe affected towns within the plume exposure emergency planning zone. In a GeneralEmergency, the steps listed in the Site Area Emergency Response section and thefollowing are performed:1. The Emergency Director may request that other personnel be mobilized insupport of Vermont Yankee through activation of the Corporate EmergencyCenter;2. Other nuclear industry resources are alerted and requested to renderappropriate assistance;3. The full resources of the National Response Framework are activated; and4. Dissemination of information and instructions associated with protectiveactions to the public is the principal focus of all response organizations. Theplant fully participates in these efforts by providing detailed emergencycondition information.9.3. Emergency De-Escalation and Termination CriteriaClassification of an accident condition requires that the plant operation staff recognize thatpre-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 offsiteradiological conditions in conjunction with the pre-established EALs; (2) review of plant andoffsite conditions with offsite authorities; and (3) concurrence by offsite authorities as to theappropriate time frame required to implement de-escalation.Emergency PlanRevision 55Page 73 of 123Entergy Vermont Yankee De-escalation from a Notification of Unusual Event to a recovery phase requires satisfyingthe 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 undercontrol, and are not expected to deteriorate further.De-escalation from emergency classes greater than the Notification of Unusual Event levelto a recovery phase requires satisfying all the criteria stated in Items 1 through 6 above andthat the States of Vermont and New Hampshire, and the Commonwealth of Massachusettsreach agreement with the Emergency Director or designee that there is no longer a needfor either consideration of further public protective action or surveillance related to publicprotective action.When plant conditions allow de-escalation in the emergency class to a recovery phase, theEmergency Director directs the emergency response organization to perform certainresponse actions prior to implementing any change. These actions include:1. Notification of all plant emergency management personnel of the pendingchange;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; and5. Announcement of the transition over the plant page system.Emergency PlanRevision 55Page 74 of 123Entergy Vermont Yankee TABLE 9.1(Page 1 of 2)VERMONT YANKEE EMERGENCY RESPONSEEMERGENCY CENTERNOTIFICATION OF UNUSUAL EVENTActivation at the discretion of theEmergency Plant ManagerALERT OR SITE AREA OR GENERALEMERGENCYEmergency Plant ManagerTechnical Support CenterMaintenance Coordinator(Electrical/Mechanical/l&C)Radiological CoordinatorEngineering Coordinator(Project, System, Design)Operations CoordinatorOSC ManagerRadiation Protection StaffChemistry StaffOperations Support CenterNot activatedSpare AOs/CROs/NCOsControl Instrument SpecialistsPlant MechanicsEmergency PlanRevision 55Page 75 of 123Entergy Vermont Yankee TABLE 9.1 (Continued)(Page 2 of 2)VERMONT YANKEE EMERGENCY RESPONSEEMERGENCY CENTEREmergency OperationsFacility/Recovery CenterNOTIFICATION OF UNUSUALEVENTActivation at the discretion of theEmergency Plant ManagerALERT OR SITE AREA OR GENERALEMERGENCYEmergency DirectorOffsite CommunicatorTechnical AdvisorAdministration and Logistics CoordinatorRadiological Assessment Coordinator*Site/Offsite Monitoring TeamsJoint Information CenterNot ActivatedCompany Spokesperson*Deployed from OSC and report to Radiological Assessment CoordinatorEmergency PlanRevision 55Page 76 of 123Entergy Vermont Yankee (SHIFT, MANAGERClassify incident and notify:InFormi/NASLSTATE POLICE 3 STATESNotify State Authorities and Implement State Radiological EmergencyResponse Plan]NRCImplements National Response FrameworkIGai-tronicsPLANT SECURITYIERONPLANT RESPONSE PERSONNELRespond asassigned3Figure 9.1Notification PlanEmergency PlanRevision 55Page 77 of 123Entergy Vermont Yankee 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES10.1. Radiological Assessment10.1.1. Deleted10.1.2. Variable Trajectory Atmospheric Dispersion/Dose Projection CapabilityI Vermont Yankee utilizes a plume tracking/dose projection system, which is capable ofproviding near real time offsite dose estimated for actual meteorological and radiologicalI accident conditions. The system assumes a variable trajectory, plume segment transportmodel designed to handle the site-specific atmospheric dispersion characteristicsassociated with the Vermont Yankee Nuclear Power Station site. Both continuous andintermittent releases for either ground or stack release points can be evaluated. Theeffects of release height, building wake entrainment, momentum plume rise, precipitationand terrain height can be assessed in the evaluation. Plume trajectories are based ononsite meteorological tower information and topography of the Connecticut River Valley.The model combines complex plume transport algorithms with dose assessmentalgorithms. The model is programmed on a personal computer. The program is designedto graphically display the calculated plume characteristics on a 10-mile Vermont YankeeEPZ site map while providing transcripts of all dispersion and dose calculations.10.1.3. Evaluation of Offsite Air SamplesVermont 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 downwindfrom 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 Facilitywhere they are analyzed to determine radionuclide concentrations. These field results canbe projected to other distances of interest.Particular attention is given to observed iodine concentrations. Air samples are analyzed ina multi-step process. The first step involves field analysis of the sample which measuresthe gross radioactivity collected in the silver zeolite cartridge and filter paper using apancake GM detector. If the silver zeolite sample analysis shows a net count rate greaterthan the background count rate, the sample is immediately delivered to the EOF/RC foranalysis with greater sensitivity and accuracy (for 1-131 specifically).The projected thyroid dose is determined from the measured 1-131 concentration bymultiplying the estimate of the duration of exposure by the dose conversion factor for anadult member of the public. A nomogram has been developed specifically for this thyroiddose projection on the basis of airborne radioiodine measurements. It is shown inFigure 10.2.In addition to the measurement and evaluation of offsite direct dose rates and air samplesfor radioiodine, the offsite radiological impact assessment includes the identification ofprincipal radionuclides potentially released from the accident and significant exposurepathways.Emergency PlanRevision 55Page 78 of 123Entergy Vermont Yankee This is accomplished through an emergency sampling program in which environmentalsamples of media (water, air, soil, etc., as appropriate) are collected and subjected todetailed radionuclide analysis. The necessary analysis can be performed as described insection 6.2.6.10.2. Protective Action Recommendation CriteriaIn the event a General Emergency has been declared, Vermont Yankee immediatelyrecommends protective actions to state authorities based on plant conditions. At aminimum, the Shift Manager or Emergency Director, who is in charge of the emergencyresponse activities, recommends that the general public be advised to seek shelter for thetowns of Hinsdale, New Hampshire and Vernon, Vermont; and the towns located five milesdownwind in the affected sectors.If plant conditions indicate a severe accident exists, Vermont Yankee recommends to theappropriate state officials evacuation of the towns of Hinsdale, New Hampshire andVernon, 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 theresponding emergency personnel is to implement the sampling and analysis of releasesand/or source terms to identify if there is a radioiodine component. This sampling capabilityincludes 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 actualor potential offsite impact.Once actual source term, onsite and/or offsite field monitoring determinations have beenmade, the Vermont Yankee Emergency Director or designee provides projected offsiteTotal Effective Dose Equivalents (TEDEs) and thyroid Committed Dose Equivalents (CDEs)at various distances from the plant to the Departments of Public Health of Vermont, NewHampshire and Massachusetts. Based upon these results, the Emergency Directorrecommends protective actions in accordance with the criteria set forth in the EPAProtective Action Guides, Table 10.1.1. For environmental samples collected and analyzedby Vermont Yankee, the results of these samples are coordinated with the appropriatestate agencies, and the state agencies implement the appropriate ingestion pathwayprotective actions in accordance with the FDA/HHS document Accidental RadioactiveContamination of Human Food and Animal Feeds, issued 8/13/98. Table 10.1.2 lists theRecommended Derived Intervention Level (DIL) for each radionuclide group.10.3. Radiological Exposure ControlDuring a plant emergency, abnormally high levels of radiation and/or radioactivity may beencountered. These levels may range from slightly above those experienced during normalplant 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 theemergency or for life-saving purposes; steps should be taken to minimize personnelexposure from external and/or internal sources of radiation.Emergency PlanRevision 55Page 79 of 123Entergy Vermont Yankee Table 10.2 specifies the guidelines on emergency dose limits for personnel providingemergency response duties which is consistent with the Environmental Protection AgencyEmergency Worker Dose Limit Guides (EPA 400-R-92-001). The Shift Manager initiallyhas the responsibility to authorize emergency dose commitments until relieved by theEmergency Plant Manager. This authorization is coordinated with the assistance of theRadiological Coordinator and Radiation Protection Technicians as needed. Exposure toindividuals providing emergency functions will be consistent with the limits specified inTable 10.2 with every attempt made to keep exposures ALARA.The Radiological Coordinator is responsible for developing emergency radiologicalprotection programs for plant staff support personnel. Emergency kits in each emergencycenter are provided with self-reading dosimeters (both high and low range). Each memberreporting to the site will be provided a DLR badge. Dose records will be maintained at eachcenter based upon the results of the self-reading dosimeters. This information iscross-referenced with the DLR badge data, as soon as they can be processed at theEmergency Operations Facility/Recovery Center. The capability exists for the emergencyprocessing of DLRs on a 24-hour per day basis, if necessary, through a General ServicesAgreement with Landauer Inc. Emergency workers are instructed to read self indicatingdosimeters frequently, and DLRs may be processed with increased periodicity.10.4. Protective Measures10.4.1. Site Personnel AccountabilityThe goal of the personnel accountability process is to account for personnel within 30minutes of the emergency declaration of an Alert or higher. Accountability for a Notificationof Unusual Event is at the discretion of the Emergency Plant Manager. Plant proceduresrequire Security personnel at the gate to maintain a list of personnel entering or leaving thesite during a site evacuation. Emergency Response Facility Managers are responsible foraccounting for their staff as they report to their facility. Each facility maintains anorganizational sign-in method which enhances this reporting process. All reports areprovided to the Emergency Plant Manager in the Technical Support Center, who initiatessearch and rescue actions for any missing personnel. Plant security provides assistancefor this accountability effort and aids in the control of personnel during extended emergencyoperations.Accountability may be modified or suspended if the safety of personnel may be jeopardizedby a Security event or other event hazardous to personnel.Emergency PlanRevision 55Page 80 of 123Entergy Vermont Yankee 10.4.2.Site Egress Control MethodsAll visitors and contractors are evacuated from the plant under the Alert, Site Area orGeneral Emergency conditions. At the Site Area or General Emergency all visitors andcontractors are directed to report to the EOF/RC for monitoring. Emergency personnelassigned to the EOF/RC and other unassigned plant personnel, report immediately to theEOF/RC, and are monitored upon arrival at the facility. If a Code Red Security event hasbeen declared, evacuation and accountability may put personnel at risk. In these securitysituations, evacuation and accountability may be suspended until directed by Security.Plant evacuees are advised of area evacuation routes prior to being released. Appendix Fprovides evacuation time estimates for the plume exposure EPZ, and also details the majorevacuation routes that could be used in the area. Access to the plant is not allowed unlesspersonnel are specifically authorized.10.4.3. Decontamination CapabilityThe in-plant decontamination facility is located in the Operations Support Center. Wastegenerated through the use of this system is collected and processed by the plant liquidradwaste system. Survey instrumentation for personnel "frisking" and sensitive bodyburden monitoring equipment are available in various plant locations.Decontamination at the EOF/RC is provided by using washcloths, which are disposed of byplacing them in a 55-gallon drum. If conditions warrant alternative means, the EOF/RC hasemergency decontamination capability (decontamination shower with the waste draining into a holding tank). After accident conditions have been terminated, the holding tank issampled to ascertain whether abnormal radiological levels exist. Depending upon theactivity present and the isotopic determination, plans will be developed to remove the wastefor disposal. Contaminated personnel not required for EOF activation will be directed toState Reception Centers.10.4.4. Use of Onsite Protective Equipment and SuppliesThe plant supplies of personnel radiation protection equipment and gear are utilized tosupport the emergency response effort. Equipment such as respiratory protection gear, alltypes of protective clothing, and a supply of potassium Iodide is assigned to emergencyresponse organization members in accordance with established plant radiation protectioncriteria. Radiation guideline action levels for a range of plant radiological conditions areshown in Table 10.3.10.4.5. Fire Protection EquipmentThe plant maintains sufficient respiratory equipment (i.e., Scott Air Pacs and spare aircylinders), to support emergency response personnel in the event of a fire. Additionally,Vermont Yankee maintains a letter of agreement with the Brattleboro Fire Department forrecharging Scott Air Pac cylinders during an emergency.Emergency PlanRevision 55Page 81 of 123Entergy Vermont Yankee 10.5. Aid to Affected Personnel10.5.1.Medical TreatmentIn-plant medical supplies are provided in the Operations Support Center. Medical responseis provided by on-shift Fire Brigade members trained in basic first-aid and Cardiopulmonaryresuscitation (CPR).Arrangements exist with the hospitals indicated in Section 8.4.1. Both hospitals participatein medical emergency drills. Figure 10.3 shows hospitals within the ingestion exposureEPZ of Vermont Yankee, which have the capability to handle radiation emergencies.10.5.2.Medical TransportationArrangements exist with Rescue, Inc., to provide 24-hour ambulance service for emergencytransportation of plant personnel for offsite treatment. The ambulance service is capable ofradio communications with the hospital while en route with a patient. Normaltelecommunication channels are used in notifying the ambulance service dispatch center.Rescue, Inc. personnel are provided with specific training by Vermont Yankee on the healthphysics considerations associated with radioactively contaminated personnel and siteaccess control measures.10.6. Protective Actions for Onsite PersonnelA range of protective actions to protect onsite personnel during hostile action is provided toensure the continued ability to maintain equipment important to safe storage of spent fueland perform the functions of the emergency plan.Emergency PlanRevision 55Page 82 of 123Entergy Vermont Yankee TABLE 10.1.1EPA PROTECTIVE ACTION GUIDELINESTotal Effective Dose Committed Dose Protective ActionEquivalent (TEDE) Equivalent (CDE) to theThyroid>1 rem >5 rem EVACUATION(Sheltering may be preferredprotective action if the followingare present:* Severe weather,* Competing disasters,* Local physical factors whichimpede evacuationLOCAL/STATE OFFSITEOFFICIALS WILL DETERMINETHE SIGNIFICANCE OF THESEFACTORS TO THE PARSUBSEQUENT TO THEISSUANCE OF THE PAR BY VY.)Emergency PlanRevision 55Page 83 of 123Entergy Vermont Yankee TABLE 10.1.2RECOMMENDED DERIVED INTERVENTION LEVEL (DIL)OR CRITERION FOR EACH RADIONUCLIDE GROUP(a)(b)All Components Of The DietRadionuclide Group (Bg/kg) (pCi/kg)Sr-90 160 43001-131 170 4600Cs-1 34 + Cs-1 37 1200 32,000Pu-238 + Pu-239 + Am-241 2 54Ru-103 + Ru-106' C3 + C6 <1 C3 + C6 <16800 450 180,000 12,000Notes:(a)The DIL for each radionuclide group (except for Ru-1 03 + Ru-1 06) is appliedindependently. Each DIL applies to the sum of the concentrations of theradionuclides in the group at the time of measurement.(b) Applicable to foods as prepared for consumption. For dried or concentratedproducts such as powdered milk or concentrated juices, adjust by a factorappropriate to reconstitution, and assume the reconstitution water is notcontaminated. For spices, which are consumed in very small quantities, use adilution factor of 10.(C) Due to the large difference in DILs for Ru-1 03 and Ru-1 06, the individualconcentrations of Ru-1 03 and Ru-1 06 are divided by their respective DILs and thensummed. The sum must be less than one. C3 and C6 are the concentrations, at thetime 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 PlanRevision 55Page 84 of 123Entergy Vermont Yankee TABLE 10.2EMERGENCY DOSE LIMITS(a)(refer to Notes 1 and 2)Dose Limit (refer to Note 3) Work Activity Condition5 Rem Total Effective Dose Maintain ALARA and to extentEquivalent (TEDE) All practicable limit emergencyworkers to these limits10 Rem TEDE Protecting Valuable Property Lower dose not practicable25 Rem TEDE Lifesaving or Protection of Lower dose not practicableLarge PopulationLifesaving or Protection of Only on a voluntary basis to75 Rem TEDE Large Population persons fully aware of therisks involvedNOTES: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. Olderworkers with low lifetime accumulated effective dose should be given priority.c. The individual(s) awareness of biological consequences that such as exposure canhave, including the risks associated with exposure of a developing embryo/fetus forfemale 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 thetask.2. After the emergency has been concluded, doses received by emergency workers arerequired 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 andextremities) are three and ten times the listed values, respectively.a EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for NuclearIncidents, Revised 1991Emergency PlanRevision 55Page 85 of 123Entergy Vermont Yankee TABLE 10.3EMERGENCY CENTER HABITABILITY AND PROTECTIVE ACTION CRITERIA1. A background dose rate of 50 mRem/hr will increase the frequency of radiationmonitoring in the center and require an immediate evaluation of the accumulatedTEDE at the affected center.2. A reading of 1 Rem on the high-range or alarming dosimeter will initiate planning forpossible evacuation to the alternate center.a) If the TSC has to be evacuated,1) The Emergency Plant Manager and immediate staff deemednecessary to deal with the emergency should relocate to the ControlRoom and continue their respective roles in the Emergency ResponseOrganization.2) Remaining TSC staff should relocate to the EOF/RC in support of theirrespective disciplines or be otherwise reassigned by the Administrationand Logistics Coordinator.b) If the OSC has to be evacuated, the TSC will determine an alternate area forrelocation.3. A reading of 4 Rem on the high-range or alarming dosimeter will initiate evaluation ofthe need for a phased evacuation.4. If center personnel have been or may be exposed to elevated radioiodine airconcentrations in excess of 500 millirem/hr (4.0 x 10.6 microcuries/cc), evaluate theneed for administration of KI for center staff and relief shift personnel.Emergency PlanRevision 55Page 86 of 123Entergy Vermont Yankee Figure 10.1DeletedEmergency PlanRevision 55Page 87 of 123Entergy Vermont Yankee 100000100001000ilii'UUI-)~1I..Gd010010II 100HR50 HRS20 HR 3=8 HR4 HR2HR1 HR1.OOE-040.010.011.OOE-091.OOE-08 1.00E-07 1.OOE-06 1.00E-051-131 Air Concentration (uCilcc)Figure 10.2Field Sample Thyroid Dose NomogramEmergency PlanRevision 55Page 88 of 123Entergy 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 CenterWINDHAM Keene-.HILLSBORO* Brattleboro Memorial Hasp." + BrattleboroBennington Vermont Yankee':* Putnam Memorial , .North Adams Hosp. -,* "' L~tl NorthAdams " .RANKLIN. .* -, l : FRANK ILIN .J-- Franklin Medical Center*Greenfield WORCESTER* IiI.-~~BERKSHIRE -- 2Berkshire Medical Care HAMPSHiREPittsfield , +CoeyDcsnHs* * -NorthamptonCCTDUTCHESS LITCHFIELD 2 HARTFORD

• TOLLAND W INDHAM0 10 20 30 40 50Miles( Hospital can handle contaminated patients.Figure 10.3Medical Facilities within 50 Miles of Vermont YankeeCapable of Handling Emergency Medical CasesEmergency PlanRevision 55Page 89 of 123Entergy Vermont Yankee 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION11.1. Emergency NotificationThe Shift Manager is responsible for the notification of the State Police of Vermont, NewHampshire, and Massachusetts. Notification is made within 15 minutes of emergencyclassification and is the initial link to offsite authorities for the activation of offsite emergencyresponse plans, which includes emergency public notification if the emergency conditionswarrant.The format and contents of the initial message between the plant and State Policedispatchers are specified in notification procedures and have been established with thereview and agreement of those state authorities responsible for state plans.As soon as contacted via the notification procedure, the Department of Public Health ofVermont, Massachusetts and New Hampshire may call Vermont Yankee and request thefollowing information:1. Date, time and class of the emergency;2. Type and quantity of release, height of release, and estimatedduration/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 doserates at various distances from the plant;5. Emergency response actions underway; and6. Recommended protective actions.These follow-up reports are provided on an as-needed basis until such time that theemergency condition has been terminated in agreement with the States of Vermont andNew Hampshire, Commonwealth of Massachusetts, and Vermont Yankee plantmanagement.11.2. Public NotificationThe prompt public notification methods in the Vermont Yankee area utilize, radio,television, sirens and weather alert receivers, police and fire department mobile loudhailersand sirens, and door-to-door notification should that be required. Details of this system areprovided in Appendix H.Emergency PlanRevision 55Page 90 of 123Entergy Vermont Yankee 11.3. Public InformationAny 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 aresaying. Consequently, Vermont Yankee has planned for the establishment of a JointInformation Center for the purpose of providing coordinated press releases during anaccident.For a Notification of Unusual Event, the Manager of Communications is notified of theincident by telephone or paging system. The Manager of Communications, or designatedalternate, is responsible for writing any official statements or press releases concerning theincident. Prior to release, statements are approved by an officer of the company ordesignee. Information is released directly to the press pool and the "Status Phones" areupdated with this information. In addition, the Manager of Communications notifies theappropriate departmental staff and the corporate public affairs office.For an Alert, Site Area Emergency and a General emergency, the Joint Information Centeris activated and fully staffed.The Technical Advisor and required staff report to the EOF/RC for coordinating theaccident information between the plant and the Joint Information Center. The JointInformation Center is staffed and provides immediate accessibility to information files andresources for the Company Spokesperson (Manager of Communications, or designatedalternate) and/or the Joint Information Center staff.Regular press conferences are held at the Joint Information Center, directed by theCompany Spokesperson in conjunction with appropriate state and federal organizations.Vermont Yankee can provide 24-hour coverage at the Joint Information Center to ensuretimely updates and answers to questions from visiting media representatives.As part of Vermont Yankee's full disclosure policy, Vermont Yankee has initiated a publicinquiry phone for media and public use. Normally, a prerecorded message provides, on adaily basis, routine plant information, changes in plant conditions, and other items ofinterest. During an emergency, the phone is used to relay and provide up-to-date statusreports regarding the situation.Joint Information Center personnel monitor local radio and television for erroneousinformation concerning accident conditions. When misinformation is recognized, correctiveaction is taken.Emergency PlanRevision 55Page 91 of 123Entergy Vermont Yankee Communication is provided between the Joint Information Center and the EOF/RC and forstate and federal agency use. Public information documentation covering the followingareas 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; and4. Planned protective actions to be implemented by state and local authorities.Vermont Yankee assists the States of Vermont and New Hampshire and theCommonwealth of Massachusetts, to develop and ensure for dissemination on a yearlybasis, brochures, calendars, and posters which provide the public with emergency planningarrangements.The Vermont Yankee Communications Department conducts annual information programsto acquaint the news media with information concerning radiation, emergency publicinformation procedures, the emergency classification system and a general review of plantcharacteristics. Local and state media are invited and encouraged to attend.Emergency PlanRevision 55Page 92 of 123Entergy Vermont Yankee 12.0 MAINTAINING EMERGENCY PREPAREDNESS12.1. Drills and ExercisesAn exercise tests the execution of the overall plant emergency preparedness and theintegration of this preparedness with offsite authorities. A drill is a supervised instructionperiod aimed at testing, developing and maintaining skills in a particular response function.Emergency exercises and drills are conducted to test and evaluate the adequacy ofemergency facilities, equipment, procedures, communication channels, actions ofemergency 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 ExercisesA full participation exercise shall be conducted every two years. At least one drill involvinga combination of some of the principal functional areas of emergency response shall beconducted in the interval between biennial exercises. State and offsite agencies mayparticipate in drills.12.1.2. Communication TestsTo ensure that emergency communications between the facility and offsite emergencyresponse organizations are operable, communications tests are conducted as outlinedbelow. Items 2) and 3) below can be performed as part of an Emergency plan drill orexercise.1. Communication channels with state governments within the plume exposurepathway are tested monthly;2. Communications with state Emergency Operations Center (EOCs) areconducted annually;3. Communications with assessment teams are conducted annually;4. Communications among states within the ingestion pathway are testedmonthly; and5. Communications with the NRC Headquarters Operations Officer from theControl Room, TSC and EOF are tested monthly.Emergency PlanRevision 55Page 93 of 123Entergy Vermont Yankee To ensure the reliability of the plant's call-in procedure, the following test/drill is performedas follows:Weekly functional test of the emergency notification system to test systemperformance, andQuarterly off-hours, unannounced communications drill, utilizing both thepager system and commercial telephone, to estimate emergency personnelresponse times.12.1.3. Fire DrillsTo test and evaluate the response and training of the plant's fire brigade, a number of firedrills are conducted annually.To demonstrate the coordination between the plant's fire brigade and the Vernon FireDepartment, the fire department is annually offered the opportunity to participate in anonsite fire drill.12.1.4. Medical DrillsTo evaluate the training of the facility's medical response and offsite medical response(ambulance and hospital), a medical drill is conducted annually with a simulatedcontaminated injured individual. This drill can be performed as part of an Emergency Plandrill or exercise.12.1.5. Radiological Monitoring DrillsPlant 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 aspart of an Emergency Plan drill or exercise. Radiological monitoring drills will includeinterface with State offsite monitoring efforts during the biennial exercise.12.1.6. Health Physics DrillsHealth Physics drills are conducted semi-annually involving response to, and analysis of,simulated elevated in-plant airborne and liquid samples and direct radiation measurementsin the environment. A drill can be performed as part of an Emergency Plan drill or exercise.Emergency PlanRevision 55Page 94 of 123Entergy Vermont Yankee 12.1.7. Security DrillsThe purpose of the Hostile Action-based drill is to maintain key skills, specifically thesite-specific team skills necessary to mitigate security-based events. Hostile Action-basedscenarios will be included in the drill and exercise program for exercise selection on asix-year frequency. Full implementation should include engagement of Offsite respondersand FEMA. Scenarios should address EP response actions early in the event that includeaspects such as initial classification, notification, PARs if appropriate, and protectivemeasures on site. Various scenarios should be developed to address response to differentthreat modes, various initiators or response capabilities.12.1.8. ScenariosAn Exercise/Drill Coordinator is responsible for an emergency plan drill or exercise. TheExercise/Drill Coordinator's responsibilities include developing the exercise/drill scenario,the accident time sequence, and the selection and training of the Controllers required toevaluate the effectiveness of the Vermont Yankee Emergency Preparedness Program.A scenario is prepared by the Scenario Development Group for each exercise/drill to beconducted. The scenario varies year to year and is approved by Vermont YankeeManagement. Within a six-year period, the scenario content is varied to test all the majorelements of the Emergency Plan Program. For full participation exercises, the scenariosimulates an emergency condition and sequence that calls for the mobilization of the offsiteauthorities; requires the recommendation of offsite protective actions; and allows for theevaluation 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 suchitems as simulated casualties, search and rescue of personnel, deployment ofradiological monitoring teams, and public information affairs; and6. List of Controllers.The scenarios are designed to allow free play in exercising the decision-making processassociated with such emergency response actions as exposure control, emergencyclassification and de-escalation, protective action recommendation, and the emergencymanpower augmentation process.Emergency PlanRevision 55Page 95 of 123Entergy Vermont Yankee Security based scenarios to test and evaluate security response capabilities will beconducted in accordance with security drills and exercise procedures and may beconducted during emergency plan drills or exercises.Starting times and pre-notification for exercises are coordinated with and agreed upon byall participating organizations. The scenario package is submitted to the NRC inaccordance with current regulatory guidance.12.1.9. Evaluation of ExercisesTo evaluate the performance of participating facility personnel and the adequacy ofemergency facilities, equipment and procedures during an exercise, the ExerciseCoordinator obtains qualified controllers which includes resources outside the facility toevaluate and critique the exercise.When feasible, personnel designated as controllers are assigned to an Emergency Planarea germane to their area of expertise. Controllers are provided general instructionconcerning their specific observation function. Each controller is requested to observe theimplementation of the emergency plan element assigned to him or her, and then to recordand report observed inadequacies.A critique is conducted at the conclusion of the exercise with facility personnel asdesignated by the General Manager or a designated representative. After the critique, thecontrollers submit a written evaluation to the Exercise Coordinator in which the exerciseperformance is evaluated against the objectives. All comments and/or recommendationsare documented. Controllers from State Emergency Management and Health Departmentagencies are encouraged to join the observation and critique process.Weaknesses and/or deficiencies identified in an exercise critique are processed inaccordance with the site corrective actions program.12.1.10. Emergency Plan AuditThe Vermont Yankee Emergency Plan is independently audited as part of the VermontYankee In-plant Audit Program. The audit is conducted as part of the Entergy QualityAssurance Program in accordance with 10CFR50.54(t). All aspects of emergencypreparedness, including exercise documentation, capabilities, procedures, and interfaceswith state and local governments are audited.Emergency PlanRevision 55Page 96 of 123Entergy Vermont Yankee 12.2. TrainingAll non-essential plant personnel receive annual instruction, in accordance with"Emergency Plan Training," concerning their expected response action during anemergency. Those members of the plant staff who have been assigned (per theEmergency Assistance Personnel List) to the emergency response organization receiveannual 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 normalduties;2. Define an individual's responsibilities associated with their designatedfunction;3. Familiarize individuals in emergency exposure control measures andguidelines, particularly those associated with an individual's designatedemergency functions; and4. Provide sufficient technical insight to maintain emergency functions.A portion of this training is provided by personnel's participation in unrehearsed drills oremergency exercises. During these drills and exercises, controllers check the performanceof the personnel assigned, and provide critiques which could be incorporated in futuretraining. 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 ProceduresThe Emergency Plan is reviewed at least annually and the associated implementingprocedures are reviewed at least biennially. All recommendations for changes to theEmergency Plan or associated implementing procedures are reviewed in accordance with10CFR50.54(q). The Emergency Plan is submitted to Vermont Yankee's On-Site SafetyReview Committee for approval. Written agreements with outside support organizationsand government agencies are evaluated annually to determine if these agreements are stillvalid. If agreements are not valid, then they are renewed and updated. This agreementreview is documented. Revisions to the Emergency Plan are made in accordance withcurrent regulations and guidelines. Changes to the Plan are forwarded to organization andindividuals with a responsibility for implementation of the Plan. Telephone number listingsassociated with the emergency notification process are updated quarterly.Emergency PlanRevision 55Page 97 of 123Entergy Vermont Yankee 12.4. Maintenance and Inventory of Emergency Equipment and SuppliesThe emergency equipment maintained in the Control Room, Operations Support Center,Technical Support Center, and the Emergency Operations Facility are listed in a checklistin Emergency Equipment Readiness Check, that is used to check readiness.Weekly, the Operations Department conducts a test of certain emergency communicationsequipment. At least quarterly in accordance with the emergency equipment inventoryprocedure, and subsequent to each usage, Radiation Protection Department, ChemistryDepartment, and other designated VY personnel are assigned to inventory and maintainthe emergency kits and/or equipment. Rotation of survey instruments normally used in theplant with instruments in the Emergency Kits assures that emergency equipment iscalibrated and fully operable. There are sufficient reserve instruments and equipment toreplace those that are removed from emergency kits for calibration purposes. Appendix Bcontains a list of emergency equipment by location.12.5. Responsibility for the Planning EffortThe Senior Site Executive has overall responsibility for implementation of the EmergencyPlan at Vermont Yankee. The Emergency Planning Manager is responsible for emergencyplanning and the interface with local and state governments. The Emergency PlanningManager reports offsite to the Director, Emergency Programs. The duties of theEmergency 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 areupdated and current with the Emergency Plan;3. Schedule and ensure the conduct of emergency equipment inventories andcalibration;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 coordinatingEmergency Plan drills and exercise; and7. Maintain drill and exercise documentation and coordinate implementation ofcorrective actions deemed necessary following drills and exercises.Emergency PlanRevision 55Page 98 of 123Entergy Vermont Yankee APPENDIX AEMERGENCY CLASSIFICATION SYSTEMANDEMERGENCY ACTION LEVELS[NOTE: Reference AP 3125, Emergency Plan Classification and Action Level Scheme forthe most current revision of the EAL Charts.]Emergency PlanRevision 55Page 99 of 123Entergy Vermont Yankee APPENDIX BEMERGENCY EQUIPMENTThis Appendix contains a list of emergency equipment by location. Backup equipment isavailable 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 VermontYankee in an emergency.Emergency PlanRevision 55Page 100 of 123Entergy Vermont Yankee APPENDIX B (Continued)EMERGENCY EQUIPMENT INVENTORYLOCATIONMAIN TECH OPS OUTER INNERCONTROL SUPPORT SUPPORT GATE GATEEQUIPMENT ROOM CENTER CENTER EOF/RC HOUSE HOUSERespiratory Protection *Radiation Monitoring 0 0 0DosimetrySamplingCommunicationsDose AssessmentArea Map/StatusBoards °EmergencyReferences _ °_°_ °Protective ClothingDecontaminationBarrel 0Administrative SupportStatus BoardsCoolant SamplingContainment AirSampling *Stack SamplingSampling CartridgesPortable LeadShieldingEmergency Centers &Emergency RoomKeysStation SamplingCartridgesEnvironmental StationKeys °KII (A more detailed listing of emergency equipment is provided in"Emergency Equipment Readiness Check")OP-EQUIP-3506,Emergency PlanRevision 55Page 101 of 123Entergy Vermont Yankee APPENDIX B (Continued)EMERGENCY EQUIPMENT INVENTORYLOCATIONProvided by other non-affected Entergy nuclear sites, State andEQUIPMENT Federal agencies and other utilities through INPO as neededGammaSpectroscopyHigh PressureIon ChamberMobileProcessingDLR UnitPersonnel &EnvironmentalDLR BadgesEmergency PlanRevision 55Page 102 of 123Entergy Vermont Yankee APPENDIX CDELETEDEmergency PlanRevision 55Page 103 of 123Entergy Vermont Yankee APPENDIX DENVIRONMENTAL LABORATORY ANALYTICALAND DOSIMETRY SERVICESEmergency PlanRevision 55Page 104 of 123Entergy Vermont Yankee APPENDIX D (Continued)GeneralIn the event of a radiological emergency at Vermont Yankee, Laboratory services (asdescribed in 6.2.6) are available, on a 24-hour emergency call basis, to perform gammaisotopic analyses on samples taken by the plant's emergency monitoring teams. Portablegamma spectroscopy equipment can be deployed to the plant site to determine thepresence and level of contamination in samples of various media in the event of anaccidental release of radioactive material. In addition Entergy maintains a GeneralServices 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 Dosimetryprocessing.Portable Emergency Analysis EquipmentPortable analysis equipment including a shielded HPGe detector based gammaspectroscopy system complete with computerized spectral analysis capability may bedeployed to assist in an emergency response. A report of plant-related nuclideconcentrations, standard deviation, and Minimum Detectable Concentration (MDC) isforwarded to assessment personnel.Following a request from Vermont Yankee for assistance in assessing an emergencycondition, laboratory personnel will be dispatched to a designated location withinapproximately four (4) to eight (8) hours. Upon arrival, laboratory personnel will determinethe presence and level of contamination in samples of various media (air cartridges, airfilters, vegetation, water) collected by Plant Field Sampling Teams.Emergency DLR ServicesThe capability exists for the emergency processing of DLRs on a 24-hour per day basis, ifnecessary, through a General Services Agreement with Landauer Inc. Emergency workersare instructed to read self indicating dosimeters frequently, and DLRs may be processedwith increased periodicity.Portable Body Burden ServiceA WBC System is comprised of a portable shielded HPGe detector, interfaced to aPC-based ADCI/MCA and IBM compatible portable computer may be acquired from theother industry facilities. The analytical methodology provides a whole body scan andidentifies 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 PlanRevision 55Page 105 of 123Entergy Vermont Yankee APPENDIX ELETTERS OF AGREEMENTLetters of agreement in effect between Vermont Yankee and the offsite authorities andorganizations, 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 followingorganizations in support of Vermont Yankee Emergency Response.Letters of Agreement have been ascertained with offsite groups to provide on-site aid in theevent of an emergency situation, including those resulting from hostile actions at VermontYankee.Ambulance Service: Twenty-four (24) hour ambulance service is provided by Rescue Inc.Mutual aid backup from other ambulance services provides for additional emergencymedical services, ambulances and EMS personnel. Onsite procedures contain instructionsthat 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 medicalassistance and handling of patients.Hospitals: Brattleboro Memorial Hospital and Baystate Franklin Medical Center haveagreed to accept patients from Vermont Yankee who have been injured, contaminated orirradiated.Fire: Offsite firefighting support is provided by the Vernon and Brattleboro FireDepartments, as resources permit, with mutual aid backup from other fire departments.Law Enforcement: When notified that assistance is needed, Security will notify the LeadLocal Law Enforcement Agency (LLEA). The handling of security matters, including thoseinvolving hostile action for Vermont Yankee is covered in the Vermont Yankee SecurityPlan and are classified as safeguards information.Emergency PlanRevision 55Page 106 of 123Entergy Vermont Yankee APPENDIX E (Continued)Letters of Agreement1. State of Massachusetts2. State of New Hampshire3. State of Vermont4. Baystate Franklin Medical Center5. National Weather Service (NOAA)6 Brattleboro Memorial Hospital7. Rescue, Inc. Ambulance Service8. Vernon Fire Department9. Brattleboro Fire Department10. Institute of Nuclear Power Operations11. Town of Vernon12. Department of Energy13. DOE -REAC/TS14. Deleted15. State of Massachusetts Alert & Notification System16. State of New Hampshire Alert & Notification System17. State of Vermont Alert & Notification System18. Landmark College19. Law Enforcement *All letters of agreement from Local Law Enforcement Authorities as required by thePhysical Security Plan are classified as Safeguards Information and as such aremaintained by Security.Emergency PlanRevision 55Page 107 of 123Entergy Vermont Yankee APPENDIX FEVACUATION TIME ESTIMATESThe Evacuation Time Estimate for Vermont Yankee Nuclear Power Station is maintainedas a separate document. The Evacuation Time Estimate is provided to offsite agencieswhen it is updated.Emergency PlanRevision 55Page 108 of 123Entergy Vermont Yankee APPENDIX GINDEX OF EMERGENCY PLAN IMPLEMENTINGPROCEDURES AND SUPPORT PLANSEmergency PlanRevision 55Page 109 of 123Entergy Vermont Yankee APPENDIX G (Continued)1. EMERGENCY PLAN IMPLEMENTING PROCEDURESAP 3125EPOP-COMM-3504EPOP-EQUIP-3506EPOP-EREC-3507EPOP-MED-3508OP 3509EPOP-OSMT-3510EPOP-PAR-3511EPOP-RAD-3513EPOP-URI-10095AP 3532OP 3533OP 3534OP 3535OP 3536EPOP-CR-3540EPOP-TSC-3542EPOP-OSC-3544EPOP-EOF-3546EPOP-SEC-3547EPOP-TERM-3548AP 3549EPOP-JIC-3550EPOP-3551EPOP-3552AP 3553AP 3554EPAP-TRNG-3712AP-10049Emergency Plan Classification and Action Level SchemeEmergency CommunicationsEmergency Equipment Readiness CheckEmergency Radiation Exposure ControlOnsite Medical Emergency ProcedureEnvironmental Sample Collection during an EmergencyOffsite and Site Boundary MonitoringOffsite Protective Action RecommendationsEvaluation of Offsite Radiological ConditionsOffsite Dose Assessment using the Unified Rascal InterfaceEmergency Preparedness OrganizationPost Accident Sampling of Reactor CoolantPost Accident Sampling of Plant Stack Gaseous ReleasesPost Accident Sampling and Analysis of Primary ContainmentIn-plant Air Sample Analysis with Abnormal ConditionsControl Room Actions During an EmergencyOperation of the Technical Support CenterOperation of the Operations Support CenterOperation of the Emergency Operations Facility/RecoveryCenterSecurity Actions During an EmergencyEmergency Termination and RecoveryOffsite Emergency Preparedness SupportActivation and Operation of the Joint Information CenterOperation of the Joint Information Center When the AlternateJoint Information Center is ActivatedActivation and Operation of the Alternate Joint InformationCenterAdministration and Maintenance of the Alert and NotificationSystemEmergency Plan TeamsEmergency Plan TrainingEquipment Important to Emergency ResponseEmergency PlanRevision 55Page 110 of 123Entergy Vermont Yankee APPENDIX G (Continued)InForm Notification SystemEPAP-INFORM-1EPOP-AFA-1008V-EN-FAP-EP-00V-EN-FAP-EP-01V-EN-FAP-EP-01V-EN-EP-202V-EN-EP-301ResponseV-EN-EP-305V-EN-EP-306V-EN-EP-307V-EN-EP-308V-EN-EP-310V-EN-EP-401V-EN-EP-601V-EN-EP-80100763 Alternative Facility Activation)9 Use of KI for the Emergency Response Organization0 Severe Weather Response2 Severe Weather RecoveryEquipment Important to Emergency PreparednessEmergency Planning Assessment of Offsite EmergencyCapability Following a Natural DisasterEmergency Planning 10CFR50.54(q) Review ProgramDrills and ExercisesHostile Action Based Drills & ExercisesEmergency Planning CritiquesEmergency Response Organization Notification SystemPublic Use of Emergency Preparedness Owner Controlled AreaCorporate Emergency Center OperationsEmergency Response OrganizationEmergency PlanRevision 55Page 111 of 123Entergy Vermont Yankee APPENDIX G (Continued)II. SUPPORT PLANS*The Vermont Yankee Severe Accident Management Program (PP 7019)The Vermont Yankee Security PlanVermont Yankee Fire Protection and Safe Shutdown (SEP-FP-VTY-003)The State of Vermont Radiological Emergency Response PlanThe State of New Hampshire Radiological Emergency Response PlanThe Commonwealth of Massachusetts Radiological Emergency Response Plan forFixed-Site Nuclear FacilitiesNRC Incident Response Plan (NUREG-0728)National Response Framework (January 2008)Procedure for Admission and Management of Radioactively Contaminated Patientsat Brattleboro Memorial HospitalVermont Yankee Nuclear Power Station On-Shift Staffing AnalysisEvacuation Time EstimateThis list does not reference any of the emergency plan arrangements specifiedin Appendices D and E of this plan.Emergency PlanRevision 55Page 112 of 123Entergy Vermont Yankee APPENDIX HPUBLIC NOTIFICATION SYSTEMEmergency PlanRevision 55Page 113 of 123Entergy Vermont Yankee APPENDIX H (Continued)Vermont Yankee has completed the installation of the equipment necessary to meetthe requirements outlined in NUREG-0654 for alerting the public within the VermontYankee EPZ. The equipment consists of 37 sirens and NWS Tone-Alert receivers. Theattached town maps indicate the location of each siren.When an emergency condition exists which requires the Public Notification Systemto be activated, the emergency Management Agencies of Massachusetts, New Hampshire,and Vermont coordinate the activation of the Public Notification System (sirens, mobile PAsystems, weather alert receivers, emergency broadcasting stations, etc.). After thecoordination, the respective states notify local response organizations to activate thesystem to alert the affected population. Coordination of the three states is very importantprior to activation due to the overlap of the radio stations and sound devices outside a stateinto the other affected states. The responsibility for activating the prompt Public NotificationSystem rests with the State and Local Governments.In the event of an emergency situation, which requires rapid implementation ofalerting the public, the respective state agencies (State Police and/or EmergencyManagement) immediately notify the Emergency Alert System (EAS) stations to provideadvisory information to the public. Simultaneously, the states include the activation of thePublic 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 andproviding 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 areoutlined in the respective State Emergency Response Plans.Emergency PlanRevision 55Page 114 of 123Entergy Vermont Yankee APPENDIX H (Continued)Siren ListMap # Siren Name Siren Location1 WI Vermont Yankee, Vernon, VT2 W2 Fire Station, Vernon, VT3 VV3 Recreation Center, Vernon, VT4 BV1 Municipal Center, Brattleboro, VT5 BV2 Town Garage, Brattleboro, VT6 BV3 West Fire Station, Brattleboro, VT7 BV4 Putney Road, Brattleboro, VT8 BV5 Williams Street, Brattleboro, VT9 BV6 State Police, Route 9, Brattleboro, VT10 HN1 Fire Station, Hinsdale, NH11 HN2 Town Well, Hinsdale, NH12 WN1 Swanzey Town Line, Route 10, Winchester, NH13 WN2 Fiddle Hill Road, Winchester, NH14 WN3 Fire Station, Winchester, NH15 WN4 Town Well, Route 10, Winchester, NH16 NM1 Route 10 North, Northfield, MA17 NM2 Fire Station, Northfield, MA18 NM3 Lucky Clapp Road, Northfield, MA19 DM1 Town Garage, Bernardston, MA20 CM1 Griswoldville, Colrain, MA21 CM2 Aunt Sophie's Peak, Colrain, MA22 DM2 Hucklehill Road, Bernardston, MA23 CM3 Greenfield and Leyden Roads, Colrain, MA24 CN1 Fire Station Cupola, Chesterfield, NH25 CN2 West Chesterfield Fire Station, Chesterfield, NH26 CN3 Spofford Fire Station, Chesterfield, NH27 CN4 Highway Garage, Chesterfield, NH28 DV1 Highway Garage, Dummerston, VT29 DV2 West Dummerston Fire Station, Dummerston, VT30 DM3 Fire Station, Bernardston, MA31 GM1 Northfield Mt, Hermon School, Gill, MA32 LM1 Municipal Center, Leyden, MA33 GV1 Front of School Corner, Guilford, VT34 GV2 Stage Road, Guilford, VT35 GV3 Sportsman's Club on Cremery Road, Guilford, VT36 HN3 Filter Plant, Route 63, Hinsdale, NH37 RN1 Whipple Hill Road, Richmond, NHEmergency PlanRevision 55Page 115 of 123Entergy Vermont Yankee APPENDIX H (Continued)j_-~ Al'AMERICA&N 0 / 1SIGNAL CORPORATION MN (14.6- W) Data Zoom 12-3Emergency PlanRevision 55Page 116 of 1231 Mi11/41 11/Entergy Vermont Yankee APPENDIX H (Continued)0 1/ 2Data Zoom 12-3AMERICAN M6WCORPORATION MN (14 6 W)Emergency PlanRevision 55Page 117 of 123Entergy Vermont Yankee APPENDIX H (Continued).1,~ ~. ......; .... ." ..... ..... ... ) AMERICAN 0 4 / 1/21-31/SIGNAL' CORPORATION MN (14.6- W5 Dots Zoom 12-3Emergency PlanRevision 55Page 118 of 123'IEntergy Vermont Yankee APPENDIX H (Continued)SAMERICAN 0 Y4ON MN (14 6- W) Data Zoom 12-3Emergency PlanRevision 55Page 119 of 123Entergy Vermont Yankeenil APPENDIX H (Continued)! 11CAM(l ERICAN 0 Y4 1/ '11 % Ii1%0 *) SIGNAL CORPORATION MN 114.4' W, Oats Zoom 12-3Emergency PlanRevision 55Page 120 of 123Entergy Vermont Yankee13/4 APPENDIX H (Continued)0 % 2 % 1 11/4MN (14.5° W) Date Zoom 12-3Emergency PlanRevision 55Page 121 of 123Entergy Vermont Yankee APPENDIX H (Continued)V____ mlAMERICA 0 I 1/SIGNAL CORPORATION MN (14.6 "W Data Zoom 12-3Emergency PlanRevision 55Page 122 of 123Entergy Vermont Yankee4 2 APPENDIX H (Continued)0 '1 1/2 3/4 1 11/2 131Date Zoom 12-3WAL AMERICATN'041ýA SIGNAL CORPORATIONMN 114.6 WiEmergency PlanRevision 55Page 123 of 123Entergy Vermont Yankee'A ATTACHMENT 9.1 10CFR50.54(q) SCREENINGPAGE 1 OF 7Procedure/Document Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/Facility/Other: Vermont YankeeTitle: 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 achange 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 permanentlycease power operations in the 4th quarter of 2014.This letter acknowledges that the Vermont Yankee 10CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in thereactor vessel after the end of the operating cycle.The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changesinvolving a reduction in the minimum on-shift and emergency response organization (ERO) staffingwere 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. (Changesummary attached)The Emergency Plan and the following documents have been revised to incorporate the approved LicenseAmendment for the SAFSTOR Emergency Plan and Emergency Response Organization (ERO). Seeattached change summaries for each document.* Cancel V-EN-TQ-110, Emergency Response Organization, Rev 11 and V-EN-TQ-110-01, FleetEplan Training Course Summary, Rev 2 to the SAFSTOR Emergency Planning Training ProgramDescription* 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 Centeris 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 LimitsPart II. Activity Previously Reviewed? UYES [L NOIs this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue toAlert and Notification System Design Report? Evaluation is next partNOT required.EnterIf YES, identify bounding source document number/approval reference and justificationensure the basis for concluding the source document fully bounds the below andproposed change is documented below: complete PartVI. cnidceeboJustification:Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffingwere submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). Thesechanges were approved by the NRC upon issuance of License Amendment 261. No further evaluationrequired.El Bounding document attached (optional) References: BVY 13-079; BVY 14-018EN-EP-305 REV 3 ATrACHMENT 9.1PAGE 2 OF 710CFR50.54(q) SCREENINGProcedure/Document Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/Facility/Other: Vermont YankeeTitle: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)Part III. Applicability of Other Regulatory Change Control ProcessesCheck 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 toother documents which have a different change control process and are NOT to be included in this 50.54(q)(3)Screening.APPLICABILITY CONCLUSIONE] 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 theemergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portionof 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 PROCESSES10CFR50.54(g)Part IV. Editorial Change UYES Z NO50.54(q)(3) Continue to nextIs this activity an editorial or typographical change such as formatting, paragraph Evaluation is partnumbering, spelling, or punctuation that does not change intent? NOT required.Justification: Enterjustification andcomplete PartVI.Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard functionidentified 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] El2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 Elstaffing) in accordance with the emergency plan. [1]3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] LI4. The process for timely augmentation of onshift staff is established and maintained. [2] El5. 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] El7. A standard scheme of emergency classification and action levels is in use. [4] El8. 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 LIinstructions 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 ElNotification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANSdesign report and supporting FEMA approval letter. [5]11. Systems are established for prompt communication among principal emergency responseorganizations. [6]EN-EP-305 REV 3 ATTACHMENT 9.1PAGE 3 OF 710CFR50.54(q) SCREENINGProcedure/Document Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/Facility/Other: Vermont YankeeTitle: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)12. Systems are established for prompt communication to emergency response personnel. [6] El13. Emergency preparedness information is made available to the public on a periodic basis within the ETplume exposure pathway emergency planning zone (EPZ). [7]14. Coordinated dissemination of public information during emergencies is established. [7] El15. Adequate facilities are maintained to support emergency response. [8] El16. Adequate equipment is maintained to support emergency response. [8] El17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] El18. A range of public PARs is available for implementation during emergencies. [10] El19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are LIavailable to support the formulation of PARs and have been provided to State and localgovernmental authorities. [10]20. A range of protective actions is available for plant emergency workers during emergencies, including Elthose for hostile action events.[10]21. The resources for controlling radiological exposures for emergency workers are established. [11] I22. Arrangements are made for medical services for contaminated, injured individuals. [12] El23. Plans for recovery and reentry are developed. [13] EL24. A drill and exercise program (including radiological, medical, health physics and other program Elareas) is established. [14]25. Drills, exercises, and training evolutions that provide performance opportunities to develop, Elmaintain, and demonstrate key skills are assessed via a formal critique process in order to identifyweaknesses. [14]26. Identified weaknesses are corrected. [14] El27. Training is provided to emergency responders. [15] El.28. Responsibility for emergency plan development and review is established. [16] El29. Planners responsible for emergency plan development and maintenance are properly trained. [16] ElEN-EP-305 REV 3 ATTACHMENT 9.1PAGE 4 OF 7IOCFR50.54(q) SCREENINGProcedurelDocument Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/FacilitylOther: Vermont YankeeTitle: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)APPLICABILITY CONCLUSIONO If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below andcomplete Part VI.Ui If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.BASIS FOR CONCLUSIONPart 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 /2/4/15Nuclear EP Project ManagerApprover Name (Print) Approver Signature DaMP McKenney ..EP manager or designee 9- "VEN-EP-305 REV 3 ATTACHMENT 9.1 IOCFR50.54(q) SCREENINGPAGE 5 OF 7ProcedurelDocument Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/FacilitylOther: Vermont YankeeTitle: 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 BVY14-018EPOP-TSC-3542, Operation of the Technical Support Center (TSC). Rev 02Updated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* TSC Manager* Reactor Engineer* Manpower and Planning Liaison* TSC Communicator* TSC Engineer* IT SpecialistEPOP-OSC-3544. Operation of the Operations Support Center (OSC). Rev 01Updated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* Operations Support* I&C/Electrical Coordinator* Mechanical Coordinator* Rad/Chem Coordinator* Work Control Coordinator* OSC Log KeeperEPOP-EOF-3546. Emer-gency Operations Facility/Recovery Center (EOF/RC). Rev 03Updated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* EOF Manager* EOF Communicator* Public Information Liaison* Emergency Planning Coordinator* IT Specialist* EOF Log KeeperEPOP-JIC-3550. Activation and Operation of the Joint Information Center, Rev 01Updated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* Information Coordinator* Press Release Writer* Logistics Coordinator* Technical Assistant* JIC Log Keeper* Inquiry Response Coordinator* Media Monitor/Status Phone Recorder* CredentialingEN-EP-305 REV 3 ATTACHMENT 9.1 10CFR5O.54(q) SCREENINGPAGE 6 OF 7Procedure/Document Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/Facility/Other: Vermont YankeeTitle: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)EPOP-3551. Operation of the Joint Information Center when the Alternate Joint InformationCenter is Activated, Rev 01Updated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* Information Coordinator* Press Release Writer* Logistics Coordinator* Technical Assistant* Inquiry Response Coordinator* Media Monitor/Status Phone RecorderEPOP-3552. Activation and Operation of the Alternate Joint Information Center, Rev 01Updated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* Logistics Coordinator* Credentialing* JIC Log KeeperV-EN-EP-801, Emergency Response OrganizationUpdated procedure to match the post-shutdown Emergency Response Organization, includingdeletion of the following positions:* TSC Manager* Reactor Engineer* Manpower and Planning Liaison* TSC Communicator* TSC Engineer* IT Specialist* Operations SupportI 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* CredentialingRemoved all information pertaining to other Entergy sitesEN-EP-305 REV 3 ATTACHMENT 9.1PAGE 7 OF 710CFR50.54(q) SCREENINGProcedure/Document Number: Emergency Plan & Emergency Plan Revision: VariousImplementing ProceduresEquipment/FacilitylOther: Vermont YankeeTitle: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I)AP 0894, Staffinq LimitsRevised on shift staffing to match the License Amendment 261 from the NRCEN-EP-305 REV 3 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 1 OF 52I. OVERVIEW PAD Rev. #: 0Facility: Vermont YankeeProposed Activity / Document: Emergency Plan Change/Rev. #: 55Description 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 staffinglevels 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 REVIEWProvide 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 PlanKeywords used: InForm, Notification System, Utility Microwave, Emergency ResponseData System, ERDS, Medical, URI, METPAC, Dose Assessmentb. List relevant sections of controlled electronic documents reviewed:UFSAR -Section 7.15, Process Computer System; Section 13.6, Emergency PlanEmergency Plan -Entire documentEN-LI-100 REV. 16 ATTACHMENT 9.1PAGE 2 OF 522. Documents reviewed manually (hardcopy):PROCESS APPLICABILITY DETERMINATION FORMEmergency 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 & 10.33. For those documents that are not reviewed either electronically or manually, use thespecific questions provided in Sections III and IV of Attachment 9.2 of EN-LI-100 asneeded. 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 werereviewed and no LBD changes were identified.EN-LI-100 REV. 16 ATTACHMENT 9.1PROCESS APPLICABILITY DETERMINATION FORMPAGE 3 OF 52III. PROCESS REVIEWDoes 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? Associatedregulations and procedures are identified with each process below.PROCESS (Regulations I Procedures) YES NOý REVIEW RESULTSChemistry I Effluents El 0Radwaste 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] 0DInservice Testing Program (10 CFR 50.55a I EN-DC-332) El 0Maintenance 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 0Appendix J / EN-DC-334)PROCESS (Regulatlons/Procedures) YES NO N/A REVIEW RESULTSFlex Program (NRC Order EA.12-491FLEX Program) (10CFR50.59 I El El 0Contact Design Engineering)NOTE: The date for individual Site Implementation of the FLEX Program isnot the same for all sites. All sites are required to implement a FLEX programper NRC Order EA-1 2-49. N/A may be used for this process by sites thathave not completed implementation of a FLEX program. Contact DesignEngineering if further assistance is needed.IF any box is checked "Yes," THEN contact the appropriate department to ensure that the proposedchange is acceptable and document the results in the REVIEW RESULTS column.EN-LI-I00 REV. 16 ATTACHMENT 9.1PROCESS APPLICABILITY DETERMINATION FORMPAGE 4 OF 52IV. LICENSING BASIS DOCUMENT REVIEWDoes 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 BasisDocument(s)? Associated regulations and procedures are identified with each Licensing BasisDocument 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 AnalysislFireHazards Analysis (FSAIFHA)] El 0OL Condition, 10 CFR 50.48 / EN-DC-128)Emergency Plan (10 CFR 50.54(q) / EN-EP-305) 0 El Screened lAW EN-EP-305Environmental Protection Plan(Appendix B of the OL, Environmental Evaluation / EN-EV- 115, EN-EV-1 17, El 0 No EPP at VYEN-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] 0Technical 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 TemperatureLimits Report (PTLR) (TS Administrative Controls, EN-LI-1 13, EN-LI-1 00, El 0EN-LI-101)Offslte Dose Calculation Manual (ODCM)(TS Administrative Controls or 10 CFR 50.59 / EN-LI-113 or EN-LI-100/ El 0EN-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 DataSystem have been submitted toLicensingStorage Cask Certificate of Compliance (10 CFR 72.244/ EN-LI-113) El* 0Cask 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* 09NRC Commitments and Obligations (EN-LI-110) 10Site 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 inaccordance with the referenced procedures. Prepare an LBDCR per procedure EN-LI-113, asrequired, if a LBD is to be changed, and document any affected sections or the LBDCR #. Brieflydiscuss how the LBD is affected in Section VII.A.EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMATTACHMENT 9.1PROCESs APPLICABILITY DETERMINATION FORMPAGE 5 OF 52V. 10 CFR 50.59 / 10 CFR 72.48 APPLICABILITYCan the proposed activity be dispositioned by one of the following criteria? Check the appropriatebox (if any).El An approved, valid 50.59172.48 Evaluation covering associated aspects of the proposedactivity already exists. Reference 50.59/72.48 Evaluation # (ifapplicable) or attach documentation. Verify the previous 50.59/72.48 Evaluation remainsvalid.[ The NRC has approved the proposed activity or portions thereof or a license amendmentbeing reviewed by the NRC addresses the proposed activity. Reference the approvaldocument: 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-332See 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 and72.48 Screenings are not required. Proceed to Section VII and provide basis for conclusion inSection VIIA.Otherwise, continue to Section VI to perform a 50.59 and/or 72.48 Screening, or perform a 50.59and/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 50.59process, as allowed by the NRC in a letter to IPEC dated January 31, 1996. [Merlin Document ID:RA-96-014]EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 6 OF 52VI. 50.59 / 72.48 SCREENING REVIEW (All proposed activities should be evaluated todetermine if 50.59, 72.48 or both apply, check the boxes as appropriate)VI.A 50.59 SCREENINGEl10 CFR 50.59 applies and screening criteria are met. Document the basis for screening criteria met insection 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 asdescribed in the UFSAR; AND* Does not adversely affect a method of evaluation that demonstrates intended design function(s) ofan 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 aII 50.59 Evaluation in accordance with EN-LI-101, attach a copy of the Evaluation to this form, andproceed to Section VII.VI.B 72.48 SCREENINGEl 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 asdescribed in the CFSAR; AND" Does not adversely affect a method of evaluation that demonstrates intended design function(s) ofan 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, THENE] perform a 72.48 Evaluation in accordance with EN-LI-112, attach a copy of the Evaluation to thisform, and proceed to Section VII.EN-LI-100 REV. 16 ATTACHMENT 9.1PAGE 7 OF 52VI.B BASISPROCESS APPLICABILITY DETERMINATION FORMProvide 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. Referto NEI 96-07 Section 4.2 for guidance. Refer to NEI 12-06 Section 11.4, regarding FLEX. Provide supportingdocumentation or references as appropriate.IVII. REGULATORY REVIEW SUMMARYVII.A GENERAL REVIEW COMMENTS (Provide pertinent review details and basis for conclusions if notaddressed elsewhere in form.)The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changesinvolving a reduction in the minimum on-shift and emergency response organization (ERO) staffing weresubmitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). Thesechanges were approved by the NRC upon issuance of License Amendment 261. No additional evaluationis required for these changes.Other changes to the Emergency Plan to reflect the permanently defueled condition are evaluatedpursuant to 10 CFR 50.54(q) in accordance with EN-EP-305.VII.B CONCLUSIONS1. Is a change to an LBD being initiated?IF "Yes," THEN enter the appropriate change control process and includethis 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-101and 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-112and attach a copy to the change activity.Z Yes[- NoEj Yes0 NoE]YesNoEN-LI-I00 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 8 OF 52VIII. SIGNATURES 1Preparer: Justine Anderson/ 9'I /ENVY/ Eplan/ 1/16/15Name (print) / Signature I Company / Department / DateReviewer: Phil Couture/ Approved per telecon /ENVY/ Licensing/ 2/4/15Name (print) I Signature / Company I Department I DateProcess Applicability ExclusionSite Procedure N/AChampion or Name (print) / Signature I Company I Department I DateOwner:Upon completion, forward this PAD form to the appropriate organization for record storage. If the PAD form ispart of a process that requires transmittal of documentation, including PAD forms, for record storage, thenthe PAD form need not be forwarded separately.1 The printed name, company, department, and date must be included on the form. Signatures may beobtained via electronic processes (e.g., PCRS, ER processes, Asset Suite signature), manual methods (e.g.,ink signature), e-mail, or telecommunication. If using an e-mail, attach it to this form.EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 9 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable of Contents -Updated page numbers and Editorial revision to reflectSection headings to reflect changes described below,changes described below, including updated pageincluding updated page numbers numbers and deletion ofand deletion of Section 6.2.5 Section 6.2.5 (Post Accident(Post Accident Sampling) and Sampling) and Section 7.10Section 7.10 (Emergency (Emergency Response DataResponse Data System). System).Table of Contents -Appendix C Initial Offsite Dose (Deleted) VY will no longer be anAppendices Rate Estimate operating nuclear powerplant. Appendix C is nolonger applicable because itis based on the isotopic mixfor a Loss of CoolantAccident (LOCA).Table of Contents -List of Figure 8.1 Normal On-Shift Figure 8.1 Defueled On-Shift VY will no longer be anFigures Emergency Organization Emergency Organization operating nuclear powerplant. The title changereflects the permanentlydefueled organizationalstructure.Table of Contents -List of Figure 8.2 Vermont Yankee Figure 8.2 Vermont Yankee VY will no longer be anFigures Emergency Management Defueled Emergency operating nuclear powerOrganization Management Organization plant. The title changereflects the permanentlydefueled organizationalstructure.Table of Contents -List of Figure 8.3 Technical Support Figure 8.3 Defueled VY will no longer be anFigures Center Emergency Organization Technical Support Center operating nuclear powerEmergency Organization plant. The title changereflects the permanentlydefueled organizationalEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 10 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changestructure.Table of Contents -List of Figure 8.4 Operations (Deleted) ERO Staffing changes resultFigures Support Center Emergency in one remaining OSCOrganization position (OSC Manager)illustrated on the figure. Afigure is no longernecessary to describe theOSC organization.Table of Contents -List of Figure 8.5 Emergency Figure 8.5 Defueled VY will no longer be anFigures Operations Facility Organization Emergency Operations Facility operating nuclear powerOrganization plant. The title changereflects the permanentlydefueled organizationalstructure.Table of Contents -List of Figure 8.7 Joint Information Figure 8.7 Defueled Joint VY will no longer be anFigures Center Organization Information Center Organization operating nuclear powerplant. The title changereflects the permanentlydefueled organizationalstructure.Table of Contents -List of Figure 10.1 Vermont Yankee (Deleted) VY will no longer be anFigures Emergency Dose Rate operating nuclear powerNomogram plant. Figure 10.1 is nolonger applicable because itis based on the isotopic mixfor a LOCA.Section 2.0 -Definition of Alert -Events are in process or Alert -Events are in progress or Editorial revision to reflectAlert have occurred which involve an have occurred which involve an definition in NEI 99-01, Rev.actual or potential substantial actual or potential substantial 5degradation of the level of safety degradation of the level of safetyof the plant or a security event of the plant or a security eventthat involves probable life that involves probable lifethreatening risk to site personnel threatening risk to site personnelEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 11 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeor damage to site equipment or damage to site equipmentbecause of HOSTILE ACTION. because of HOSTILE ACTION.Any releases are expected to be Any releases are expected to belimited to small fractions of the limited to small fractions of theEPA Protective Action Guideline EPA Protective Action Guidelineexposure levels, exposure levels.Section 2.0 -Definition of Assessment Actions -Those Assessment Actions -Those Editorial revision to correctAssessment Actions actions which are take to actions which are taken to grammatical erroreffectively define the emergency effectively define the emergencysituation necessary for decisions situation necessary for decisionson specific emergency on specific emergencymeasures. measures.Section 2.0 -Definition of General Emergency -Events General Emergency -Events Editorial revision to reflectGeneral 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 5substantial core degradation or substantial core degradation ormelting with potential for loss of melting with potential for loss ofcontainment integrity or containment integrity orHOSTILE ACTION that results in HOSTILE ACTION that results inan actual loss of physical control an actual loss of physical controlof the facility. Releases can be of the facility. Releases can bereasonably expected to exceed reasonably expected to exceedEPA Protective Action Guideline EPA Protective Action Guidelineexposure levels offsite for more exposure levels offsite for morethan 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 reflectHostile 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 5to destroy equipment, takes to destroy equipment, takeshostages, and/or intimidates the hostages, and/or intimidate thelicensee to achieve an end. This licensee to achieve an end. Thisincludes attack by air, land, or includes attack by air, land, orwater using guns, explosives, water using guns, explosives,projectiles, vehicles, or other projectiles, vehicles, or otherEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 12 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changedevices used to deliver devices used to deliverdestructive force. Other acts destructive force. Other acts thatthat satisfy the overall intent may satisfy the overall intent may bebe included. HOSTILE ACTION included. HOSTILE ACTIONshould not be construed to should not be construed toinclude acts of civil disobedience include acts of civil disobedienceor felonious acts that are not part or felonious acts that are not partof a concerted attack on the of a concerted attack on theNPP. Non-terrorism-based EALs NPP. Non-terrorism-based EALsshould be used to address such should be used to address suchactivities, (e.g., violent acts activities, (e.g., violent actsbetween individuals in the owner between individuals in the ownercontrolled area). controlled area).Section 2.0 -Definition of Notification of Unusual Event Notification of Unusual Event Editorial revision to reflectNotification 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 5potential degradation of the level potential degradation of the levelof safety of the plant or indicate of safety of the plant or indicate aa security threat to facility security threat to facilityprotection has been initiated. No protection has been initiated. Noreleases of radioactive material releases of radioactive materialrequiring offsite response or requiring offsite response ormonitoring are expected unless monitoring are expected unlessfurther degradation of safety further degradation of safetysystems occurs. systems occurs.Section 2.0 -Definition of Site Area Emergency -Events Site Area Emergency -Events Editorial revision to reflectSite 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 5major failures of plant functions major failures of plant functionsneeded for protection of the needed for protection of thepublic or HOSTILE ACTION that public or HOSTILE ACTION thatresults in intentional damage or results in intentional damage ormalicious acts; (1) toward site malicious acts; (1) toward sitepersonnel or equipment that personnel or equipment thatEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 13 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changecould lead to the likely failure of could lead to the likely failure ofor; (2) that prevent effective or; (2) that prevent effectiveaccess to equipment needed for access to equipment needed forthe protection of the public. Any the protection of the public. Anyreleases are not expected to releases are not expected toresult in exposure levels which result in exposure levels whichexceed EPA Protective Action exceed EPA Protective ActionGuideline exposure levels Guideline exposure levelsbeyond the site boundary. beyond the site boundary.Section 3.2 -1st Paragraph, 5) Notify state authorities in 5) Notify state authorities in InForm added to theItem 5 Vermont, New Hampshire and Vermont, New Hampshire and Emergency Plan in Rev. 54.Massachusetts using the Massachusetts using the InFormEmergency Notification System. Notification System.Section 3.2 -1st Paragraph, 7) Use the emergency 7) Use the notification plan to The Emergency NotificationItem 7 notification system to notify notify appropriate personnel as System is a formal systemappropriate personnel as set set forth in Figure 9.1 and Table used to notify the NRCforth in Figure 9.1 and Table 9.1. 9.1. during an emergency. Thegeneric use of "emergencynotification system" in Step7 can be confusing and ismeant only to direct thecommunicator to use thenotification plan set forth inFigure 9.1 and Table 9.1 ofthe Emergency Plan and notthe Emergency NotificationSystem. Figure 9.1 isentitled "Notification Plan"and identifies the methodsused to notify various offsiteagencies.Section 4.1 Vermont Yankee Nuclear Power Vermont Yankee Nuclear Power VY will no longer be anStation is located on the west Station is located on the west operating nuclear powerbank of the Connecticut River bank of the Connecticut River plant. The Site DescriptionEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 14 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeimmediately upstream of theVernon Hydrostation, in the townof Vernon, Vermont. TheVermont Yankee Nuclear PowerStation is a boiling water reactorhaving a thermal rated power of1912 MWt. The station, shownin Figure 4.1, is located on about125 acres in Windham County,and is owned by Entergy, withthe exception of a narrow strip ofland between the ConnecticutRiver and the Vermont Yankeeproperty for which it hasperpetual rights and easementsfrom the owner, New EnglandPower Company.immediately upstream of theVernon Hydrostation, in the townof Vernon, Vermont. TheVermont Yankee Nuclear PowerStation ceased power operationsand is permanently defueled inaccordance with 10 CFR50.82(a)(1)(i) and (ii). Thestation, shown in Figure 4.1, islocated on about 125 acres inWindham County, and is ownedby Entergy, with the exception ofa narrow strip of land betweenthe Connecticut River and theVermont Yankee property forwhich it has perpetual rights andeasements from the owner, NewEngland Power Company.On January 12, 2015, ENOsubmitted a certification that adetermination to permanentlycease power operations wasmade on December 29, 2014,pursuant to 10 CFR50.82(a)(1)(i). ENO hassubmitted written certification tothe NRC, in accordance with 10CFR 50.82(a)(1) that meets therequirements of 10 CFR50.4(b)(9) certifying that fuel hasbeen permanently removed fromthe reactor vessel and placed inthe Spent Fuel Pool. Upondocketing of these certifications,the 10 CFR Part 50 license forhas been revised to indicatethe permanently shutdownand defueled condition.EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 15 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeVY no longer authorizesoperation of the reactor oremplacement or retention of fuelinto the reactor vessel, asspecified in 10 CFR 50.82(a)(2).With irradiated fuel being storedin the Spent Fuel Pool and theISFSI, the reactor, reactorcoolant system and secondarysystem are no longer inoperation and have no functionrelated to the storage of theirradiated fuel. Therefore, thepostulated accidents involvingfailure or malfunction of thereactor and reactor coolantsystem or secondary system areno longer applicable.Section 4.2 -2nd Paragraph The nearest house is 1,300 feet The nearest house is 1,300 feet Editorial. The Hinsdalefrom the Reactor Building and is from the Reactor Building and is Raceway no longerone of several west of the site. one of several west of the site. operates and reference isThe 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 fromthe Reactor Building. The the Reactor Building. Thenearest hospital, Brattleboro nearest hospital, BrattleboroMemorial, is approximately five Memorial, is approximately five(5) miles north-northwest from (5) miles north-northwest fromthe site. The nearest dairy farm the site. The nearest dairy farmis approximately 1/2-mile is approximately 1/2-milenorthwest of the site. Additional northwest of the site. Additionaldairy farms are located within a dairy farms are located within a5-mile radius of the plant. The 5-mile radius of the plant. Alargest sports facility in the nursing home is located 2 milesEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 16 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changevicinity is the Hinsdale Raceway, south of the plant. These areaslocated approximately three (3) have been noted since they havemiles from the site. For racing required special planningevents, the average attendance consideration by offsiteis approximately 4,000. A authorities in the event of anursing home is located 2 miles radiological emergency atsouth of the plant. These areas Vermont Yankee.have been noted since they haverequired special planningconsideration by offsiteauthorities in the event of aradiological emergency atVermont Yankee.Section 5.1 -1st Paragraph Notification of Unusual Event Notification of Unusual Event Editorial revision to reflectdefinition in NEI 99-01, Rev.Events are in process or have Events are in progress or haveoccurred which indicate a occurred which indicate apotential degradation of the level potential degradation of the levelof safety of the plant or indicate of safety of the plant or indicate aa security threat to facility security threat to facilityprotection has been initiated. No protection has been initiated. Noreleases of radioactive material releases of radioactive materialrequiring offsite response or requiring offsite response ormonitoring are expected unless monitoring are expected unlessfurther degradation of safety further degradation of safetysystems occurs. systems occurs.Section 5.1 -2nd Paragraph Notification of Unusual Event Notification of Unusual Event VY will no longer be anconditions do not cause serious conditions do not cause serious operating nuclear powerdamage to the plant and may not damage to the plant. The plant. A change inrequire a change in operational purpose of the Notification of operational status is not astatus. The purpose of the Unusual Event declaration is to: consideration due to theNotification of Unusual Event 1) ensure that the first step in permanently shutdown anddeclaration 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 aEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 17 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changebeen carried out; 2) bring the state of readiness; and 3) ensureoperating staff to a state of that appropriate offsitereadiness; and 3) ensure that notifications have been made inappropriate offsite notifications the event that additional supporthave been made in the event is required.that additional support isrequired.Section 5.2 -1st Paragraph Alert Alert Editorial revision to reflectEvents 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 actualor potential substantial or potential substantialdegradation of the level of safety degradation of the level of safetyof the plant or a security event of the plant or a security eventthat involves probable life that involves probable lifethreatening risk to site personnel threatening risk to site personnelor damage to site equipment or damage to site equipmentbecause of HOSTILE ACTION. because of HOSTILE ACTION.Any releases are expected to be Any releases are expected to belimited to small fractions of the limited to small fractions of theEPA Protective Action Guideline EPA Protective Action Guidelineexposure levels, exposure levels.Section 5.3 -1st Paragraph Site Area Emergency Site Area Emergency Editorial revision to reflectEvents 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 actualor likely major failures of plant or likely major failures of plantfunctions needed for protection, functions needed for protectionof the public or HOSTILE of the public or HOSTILEACTION that results in ACTION that results inintentional damage or malicious intentional damage or maliciousacts; (1) toward site personnel or acts; (1) toward site personnel orequipment that could lead to the equipment that could lead to thelikely failure of or; (2) that likely failure of or; (2) thatprevent effective access to prevent effective access toEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 18 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeequipment needed for the equipment needed for theprotection of the public. Any protection of the public. Anyreleases are not expected to releases are not expected toresult in exposure levels which result in exposure levels whichexceed EPA Protective Action exceed EPA Protective ActionGuideline exposure levels Guideline exposure levelsbeyond the site boundary. beyond the site boundary.Section 5.4 -Ist Paragraph General Emergency General Emeraencv Editorial revision to reflectEvents 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 orimminent substantial core imminent substantial coredegradation or melting with degradation or melting withpotential for loss of containment potential for loss of containmentintegrity or HOSTILE ACTION integrity or HOSTILE ACTIONthat results in an actual loss of that results in an actual loss ofphysical control of the facility, physical control of the facility.Releases can be reasonably Releases can be reasonablyexpected to exceed EPA expected to exceed EPAProtective Action Guideline Protective Action Guidelineexposure levels offsite for more exposure levels offsite for morethan 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 TSClayout.Figure 6.3 See "After" Column 0 Deleted "Radiation Protection Editorial revision toOffices" accurately depict OSC* Changed "OSC layout.Communication Center" to"OSC Manager and BriefingRoom"" Deleted "Chemistry Offices"" Changed "Briefing Room" to"Rad Protection"EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 19 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Change* Changed "Rad Prot" to "NCORoom"" 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 SampleAnalysis Laboratory"* Changed "OSMTCommunication Area" to"Monitoring TeamCommunication Area"* Changed "Rad Assessment"to "Rad Assessment Area"* Deleted "Field TeamCoordination"* 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 anSystems are located in the Systems are located in the operating nuclear powerControl Room. The Utility Control Room. In the event that plant. There will no longerMicrowave is a line-of-sight communications fail with the be a need to notify systemdedicated system used to notify NRC due to loss of the load dispatchers ofsystem load dispatchers of commercial telephone system, emergency conditions at theemergency conditions at the load dispatchers are advised that plant because the potentialplant. The telephone has Vermont Yankee will use the to disrupt the power grid willEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 20 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changebuttons marked for each load Utility Microwave System to no longer exist.dispatcher. By pushing one of provide updates of plantthe buttons on the telephone, it conditions to NRC Region I.rings automatically at theselected location. In the eventthat communications fail with theNRC due to loss of thecommercial telephone system,the load dispatchers are advisedthat Vermont Yankee will use theUtility Microwave System toprovide updates of plantconditions to NRC Region I.The Utility Radio Net is used asan alternate means of notifyingload dispatchers. Loaddispatchers have 24-hourmanning capability at theirorganizations. The systems aretested once a week with bothorganizations.Section 7.10 7.10 Emergency Response Data Deleted VY will no longer be anSystem operating nuclear powerThe Emergency Response Data plant.Section VI.1 ofSystem (ERDS) is a direct Appendix E to 10 CFR Partreal-time electronic transmission 50 indicates that ERDS isof the following types of not applicable to nuclearparameters to the NRC to assist power facilities that are shutthem in monitoring the status of down. Based on thean emergency: permanently defueledstatus, this system is no* Core and coolant system longer necessary to transmitdata, safety system parameter* Containment building data to the NRC.EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 21 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changedata, NRC Memorandum from theSRadioactivity release Director, Division ofdativit r s Preparedness anddata, and Response (NSIR) to* Site meteorological data. Regions (Division of ReactorVermont Yankee maintains a Projects) clarifies thecontinuous ERDS connection requirements forwith the NRC Operations Center. maintenance and use ofERDS by licensees whohave submitted certificationof permanent cessation ofoperations pursuant toSection 50.82, "Terminationof Licenses," in Part 50,"Domestic Licensing ofProduction and UtilizationFacilities," of Title 10 of theCode of FederalRegulations, (10 CFR Part50)." This memorandum ispublicly available in ADAMS(ML14099A520).Table 7.1: InForm added to theState Police (VT, NH, MA) 1,2 1,2,11 Emergency Plan in Rev. 54.fromCR 1,2 1,2,11State Police (VT, NH, MA) 1,2,9 1,2,9,11from EOFState EOCs (VT, NH, MA) 1,2,9,10 1, 2, 9,10, 11State EOCs (VT, NH, MA) Add InForm to Table Key as #11from EOFSection 8.1 -2nd Paragraph During normal operations, the The minimum staff on duty at the VY will no longer be anminimum staff on duty at the plant during all shifts consists of operating nuclear powerEN-LI-I00 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 22 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeplant during all shifts consists ofone (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 Technicianand security personnel asindicated in Figure 8.1. Theresponsibility for determining thestatus of the plant in anemergency is assigned to theShift Manager or, in his absencefrom the Control Room, to theControl Room Supervisor whohas the authority andresponsibility to immediatelyinitiate any emergency actions,including emergencyclassification and notification.Additional personnel areavailable on an on-call basis torespond to plant emergencies.Corrective action and repair, asoutlined in Table 8.4, isperformed by Operations staffon-shift until supplemented byadditional ERO staff.one (1) Shift Manager, one (1)Certified Fuel Handler (CFH),three (3) Non-Certified Operators(NCO), one (1) RadiationProtection Technician andsecurity personnel as indicatedin Figure 8.1. The responsibilityfor determining the status of theplant in an emergency isassigned to the Shift Manager or,in his absence from the ControlRoom, to the CFH who has theauthority and responsibility toimmediately initiate anyemergency actions, includingemergency classification andnotification. Additional personnelare available on an on-call basisto respond to plant emergencies.Corrective action and repair, asoutlined in Table 8.4, isperformed by Operations staffon-shift until supplemented byadditional ERO staff.plant. The following on-shiftpositions will be eliminated:" Shift Technical Advisor(STA)" Two (2) Control RoomOperators* Three (3) AuxiliaryOperators* Chemistry TechnicianFollowing permanentcessation of operations andremoval of fuel from thereactor vessel, Operationson-shift personnel willconsist of one (1) ShiftManager (SM), one (1)Certified Fuel Handler(CFH) and three (3) Non-Certified Operators (NCOs).Title changes for the CRS toCFH and the AO and CROto NCO were dependentupon NRC approval ofproposed changes to theVY Technical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 23 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeThese staffing levels havebeen evaluated in the VYanalysis of proposed post-shutdown on-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledcondition.-~ 4 *1-Section 8.2 -2"' ParagraphElements of the emergencyresponse plan are activatedsubsequent to an emergencydeclaration by the Shift Manager;designated company personnelare notified and will report todesignated locations. Theemergency response action ofthe personnel already presentare performed on a priority basisdepending on the emergencyconditions and the immediateneed which those conditionsdictate as determined by theonshift operations crew. Thespecific priorities facing theemergency response forces inthe various locations cannot bepre-established. They would bespecific to the nature of theemergency and variable withtime as it proceeds.Elements of the emergencyresponse plan are activatedsubsequent to an emergencydeclaration by the Shift Manager;designated company personnelare notified and will report todesignated locations. Theemergency response action ofthe personnel already presentare performed on a priority basisdepending on the emergencyconditions and the immediateneed which those conditionsdictate as determined by the on-shift operations crew. Thespecific priorities facing theemergency response forces inthe various locations cannot bepre-established. They would bespecific to the nature of theemergency and variable withtime 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 anShift Manager, Emergency Plant Shift Manager, Emergency Plant operating nuclear powerManager, or OSC Manager can Manager, or OSC Manager can plant and emplacement orEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 24 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeauthorize actions, without authorize actions, without retention of fuel into thefollowing the complete work following the complete work reactor vessel will no longerorder process, if these actions order process, if these actions be authorized. Therefore aprevent 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 anParagraph, Item 5 shift operations concerning plant shift operations concerning plant operating nuclear powerprotection of the reactor core; protection; plant and emplacement orretention of fuel into thereactor vessel will no longerbe authorized. Therefore,the need for the EmergencyPlant Manager'sresponsibilities to includeprotection of the reactorcore is no longer applicable.Section 8.2.2 -2nd A qualified manager assumes A qualified manager assumes VY will no longer be anParagraph the role of Emergency Plant the role of Emergency Plant operating nuclear powerManager under all emergency Manager under all emergency plant and emplacement orconditions. To assist the conditions. To assist the retention of fuel into theEmergency Plant Manager, the Emergency Plant Manager, the reactor vessel will no longerTSC is staffed by TSC is staffed by representatives be authorized. Therefore,representatives from the from the following departments the need to maintain afollowing departments as as depicted in Figure 8.3: Reactor Engineer in thedepicted in Figure 8.3:

• Operations TSC is no longer applicable.* Operations

• Maintenance*nMaintenanceEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 25 OF 52Emergency 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 positionwill not exist in thePermanently Defueled ERO.Duties and responsibilitieswill be transferred toremaining positions withinthe EOF.Section 8.2.10 During implementation of Severe During implementation of Severe EPOP-TSC-3542 states thatAccident Management (SAM), Accident Management (SAM), the Operations Coordinatorthe senior licensed individual in the Operations Coordinator in in the TSC assumes thethe TSC will assume the role of the TSC will assume the role of duty of SAM DecisionDecision 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 positionat the EOF/RC will request at the EOF/RC will request will not exist in themonitoring updates from the monitoring updates from the Permanently Defueled ERO.EOF Manager. Lead Offsite Liaison. Duties and responsibilitieswill be transferred toremaining positions withinthe EOF.Table 8.3, Page 3 of 3 The Public Information Liaison at The Technical Advisor at the The position of Publicthe EOF/RC relays accident EOF/RC relays accident status Information Liaison will notstatus reports to the Joint reports to the Joint Information exist in the PermanentlyInformation Center. Center. Defueled EmergencyResponse OrganizationEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 26 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Change(ERO). Duties andresponsibilities will betransferred to the TechnicalAdvisor position.Table 8.4 -Page 1 of 2,Functional Area -PlantOperations & Assessment ofOperational AspectsShift Manager (1) On ShiftCRS (I) On ShiftCRO (2) On ShiftAO (6) On ShiftSTA (1) On ShiftShift Manager (1) On ShiftCertified Fuel Handler (CFH) (1) On ShiftNon-Certified Operator (NCO) (3) On ShiftVY will no longer be anoperating nuclear powerplant. The following on-shiftpositions will be eliminated:* STA* Two (2) Control RoomOperators" Three (3) AuxiliaryOperators* Chemistry TechnicianFollowing permanentcessation of operations andremoval of fuel from thereactor vessel, Operationson-shift personnel willconsist of the SM, one (1)CFH and three (3) NCOs.Title changes for the CRS toCFH and AO and CRO toNCO were dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 27 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeapproved by the NRC byletter dated December 22,2014 (ML14217A072).These staffing levels havebeen evaluated in the VYanalysis of proposed post-shutdown on-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledcondition.STA oversight and technicalknowledge in this functionalarea will be transferred tothe Shift Manager and/orthe CFH. This transfer ofduties has been evaluatedin the VY analysis ofproposed post-shutdownon-shift staffing inconjunction with thepostulated accidentspreviously submitted to theNRC.T able 8.4 -Page 1 of 2 ; t .V w ................. ............................................................ F ............... I CF OnShift w ill no longer be anFunctional Area -STA, oMMVIS *0 30 I OmnMeComENComNSo (1,.) 39 3m operating nuclear powerso min. OtieComm.ENSComm,(2) 3 60,min..Notification/Communication; STA.,OsaeMENSC... .. plant. The STA position willMajor Tasks -Notify be eliminated.Licensee, State, local and Following permanentfederal personnel & maintain cessation of operations, thecommunication Chemistry TechnicianPosition will not beEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 28 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeresponsible for performingnotification/communicationstasks.STA assignments in thisfunctional area will betransferred to a CRS/CFH.This transfer of duties hasbeen evaluated in the VYanalysis of proposed post-shutdown on-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledcondition.Title change for the CRS toCFH was dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4 -Page 1 of 2; 1EOEmergencyftor,,) o1 ,f EOFEnergencyDirectoro(l) 1om.. I VY will no longer be anFunctional Area -Shift Sq6CsSTA Tea h Shift MgrCF.H OnShift operating nuclear powerRadiological Accident RStf(1). 30.= RPStaf(1) mi. plant. The STA and on-shiftAssessment and Support of Chemistry Tech positionsOperational AccidentEN-LI-100 REV. 16 A'TACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 29 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeAssessment; Major Tasks -Offsite Dose Assessmentwill be eliminated.STA assignments in thisfunctional area will betransferred to the ShiftManager and/or the ControlRoom Supervisor. Thistransfer of duties andremoval of the on-shiftChemistry Tech positionhave been evaluated in theVY analysis of proposedpost-shutdown on-shiftstaffing in conjunction withthe postulated accidentsthat will be applicable in thepermanently defueledcondition.Title changes for the CRS toCFH was dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4 -Page 1 of 2; 1 ShitRPtech (1) On Shift Fieldmonilonngtearns() 3 30 rin. This change does notFunctional Area -I Fieldmonitonngteams (1)' 30 rnin. Fieldmonitoring teams 6o(r,) represent a change to theRadiological Accident Field moniton, teams1 600 1 number of on-shift RPEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 30 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeAssessment and Support of Technicians. The number ofOperational Accident on-shift RP TechniciansAssessment; Major Tasks -remains one (1). TheOnsite (out of plant) change is intended to clarifyVY's RP Technician dutiesduring an emergency,consistent with Table B-1 ofNUREG-0654.Table B-1 of NUREG-0654does not identify an on-shiftposition responsible for"onsite (out of plant)"surveys. During the initialstages of an emergency, theon-shift RP Technician willbe assigned to the mostcritical tasks during theemergency response. VYmaintains the capability toaugment on-shift staff withfield monitoring teams toperform this task within 30minutes of notification of anemergency declaration.Table 8.4 -Page 1 of 2; ShitChoem..Tec, (1) On Shift Chemstaff (1) 6O.n VY will no longer be anFunctional Area -I rD staff,(1) 60 min. operating nuclear powerRadiological Accident plant. The on-shiftAssessment and Support of Chemistry Tech position willOperational Accident be eliminated.Assessment; Major Tasks -Removal of the on-shiftChemistry/Radiochemistry Chemistry Tech positionhas been evaluated in theVY analysis of proposedpost-shutdown on-shiftEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 31 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changestaffing in conjunction withthe postulated accidentsthat will be applicable in thepermanently defueledcondition.Table 8.4 -Page 1 of 2; 1STA (ON Shifi not needed inaPemrenuy \/VY will no longer be anFunctional Area -Plant I M30 R1 Defueled Condýon operating nuclear powerSystem Engineering; Major plant. The STA position willTasks -Shift Technical be eliminated.Advisor and Core Thermal STA oversight and technicalHydraulics knowledge in this functionalarea will be transferred tothe Shift Manager and/or theCRS/CFH. This transfer ofduties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing in conjunctionwith the postulatedaccidents that will beapplicable in thepermanently defueledcondition.Additionally, the need tomaintain a Reactor Engineerin the TSC is no longerapplicable.Table 8.4 -Page 1 of 2; 1 0 Shift he Defueled OrganizationFunctional Area -Repair & S contains three (3) NCOs on-Corrective Actions; Major shift. This on-shiftTasks -Mechanical complement has beenMaintenance evaluated in the VY analysisof proposed post-shutdownEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 32 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeon-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledcondition.Title changes for the AO toNCO were dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4 -Page 1 of 2;Functional Area -Repair &Corrective Actions; MajorTasks -Rad WasteOperatorIA01CRO (1) 10mFNCO 0The CRO position iseliminated in the post-shutdown condition. TheDefueled Organizationconsists of three (3) NCOson-shift. This on-shiftcomplement has beenevaluated in the VY analysisof proposed post-shutdownon-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 33 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changecondition.Title changes for the AOand CRO to NCO weredependent upon NRCapproval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4 -Page 1 of 2;Functional Area -Repair &Corrective Actions; MajorTasks -ElectricalMaintenance/Instrumentation& Control TechnicianShift AO (1*) On ShiftMaintenance (1) 30 mi.Mainenance (1) 60 (FnNCO(1-) On ShiftMaintenance (1) 30 min-Maintenance (1) [60 min.The Defueled Organizationconsists of three (3) NCOson-shift. This on-shiftcomplement has beenevaluated in the VY analysisof proposed post-shutdownon-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledcondition.Title change for the AO toNCO was dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 34 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changereferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4 -Page 2 of 2; ShfAo 2-) 2 On NCO(2-) On Shif The Defueled OrganizationFunctional Area -Protective RP (2) 30 min RP (2) 30 mi consists of three (3) NCOsRP (2) 60 min .RP (2) .60 mninActions (In Plant); Major on-shift. This on-shiftTasks -Radiation complement has beenProtection, access control, evaluated in the VY analysisHP, coverage for repair, of proposed post-shutdowncorrective actions, search & on-shift staffing inrescue, first aid & firefighting, conjunction with thepersonnel monitoring, postulated accidents thatdosimetry will be applicable in thepermanently defueledcondition.Title change for the AO toNCO was dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 35 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 8.4, Note **** May be performed by Deleted VY will no longer be anengineering aide to Shift operating nuclear powerManager (STA for ENVY) plant. The STA position willbe eliminated. STAoversight and technicalknowledge will betransferred to the ShiftManager and/or theCRS/CFH. This transfer ofduties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing in conjunctionwith the postulatedaccidents that will beapplicable in thepermanently defueledcondition.Table 8.4, Note 1 AP 0894 specifies minimum shift AP 0894 specifies minimum shift The Defueled on-shiftstaffing requirements. FB staffing requirements. FB staffing has been evaluatedrequires 5 persons per TRM and requires 5 persons per TRM and in the VY analysis ofthe Vermont Yankee Nuclear the Vermont Yankee Nuclear proposed post-shutdown on-Power Station On-Shift Staffing Power Station Analysis of shift staffing in conjunctionAnalysis. The staffing analysis is Proposed Post-Shutdown with the postulatedmaintained as a controlled On-Shift Staffing. The staffing accidents that will bedocument and is effective 30 analysis was evaluated to reflect applicable in thedays after OSRC approval. STA VY's permanently shutdown and permanently defueledand Chemistry Tech must be defueled conditions, including condition.available within 10 minutes to the on-shift staff composition andthe Control Room. VY letter to revised accident analyses.NRC dated 4/14/1981 (FVY 81-65) establishing position. VYletter to NRC 6/22/1982 (FVY82-75) Supplement -NUREG0737 Item III.A.1.2 on training ofEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 36 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeon-shift staff to support VYposition for staffing. VY letter toNRC 4/14/1981 (FVY 81-65) TMIAction Plan Item II1.A.1.2, goalfor augmentation of staff. VYletter to NRC 6/15/82 (FVY 82-70) Results of Augmentationdrills to support use of goals.Titles of ENVY ERO positionsare shown.Table 8.4, Note 2All AOs use digital dosimeterswith features for dose rate andtotal dose monitoring. AOs aretrained to self-monitor in anemergency.All NCOs use digital dosimeterswith features for dose rate andtotal dose monitoring. NCOs aretrained to self-monitor in anemergency.Title changes for the AOsand CROs to NCO weredependent upon NRCapproval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4, Note 3 ENVY has designated pager ENVY has designated ERO The Defueled Organizationholders who staff positions members who staff positions will consist of fewer than 4required 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 thisand EOF (see E Plan Figures and EOF. The minimum staff note are editorial to remove8.3 through 8.5). There are a positions required to activate the references to pagers andminimum 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. Theduty). However, all persons on OSC Manager is the onlyEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 37 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeteams are expected to respond. position required to activate andIn addition, all other ERO staff the OSC. All EROpersonnel not on pagers are personnel are expected tonotified by the emergency call-in respond when notified by thenotification system and are emergency call-in notificationexpected to respond. system.Table 8.4, Note 4The on-shift Shift Manager,CRS, STA, and Chem Techhave the capability to do initialdose assessment and PAR. TheTSC and EOF radiationassessment staff relieves themof this function.The on-shift Shift Manager andCFH have the capability to doinitial dose assessment andPAR. The TSC and EOFradiation assessment staffrelieves them of this function.VY will no longer be anoperating nuclear powerplant. The STA and on-shiftChemistry Technicianpositions will be eliminated.Title changes for the CRS toCFH were dependent uponNRC approval of proposedchanges to the VYTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).CFHs will supervise fuelhandling operations in thepermanently defueledcondition. The CRS and SMwill be qualified as CFHs.However, the SM requiresadditional qualificationbeyond the CFH training.Therefore, any reference toEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 38 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changethe CFH position throughoutthis Plan is considered to beequivalent to the CRSposition. NCOs will performduties typically associatedwith those performed byAuxiliary Operators andControl Room Operators,such as manipulation andmonitoring of plantequipment.Figure 8.1 Normal On-Shift Emergency Replaced figure with "Defueled VY will no longer be anOrganization On-Shift Emergency operating nuclear powerOrganization" figure. plant. The following on-shiftDeleted the following positions: positions will be eliminated:" Shift Technical Advisor 0 STA* Chem Tech 0 Two (2) Control Room" Control Room Operators Operators0 Three (3) AuxiliaryReplaced "Control Room OperatorsSupervisor" with "Certified Fuel 0 Chemistry TechnicianHandler" Following permanentReplaced "Auxiliary Operators" cessation of operations andwith "Non-Certified Operator" removal of fuel from thereactor vessel, Operationson-shift personnel willconsist of the SM, one (1)CFH and three (3) NCOs.Title changes for the CRS toCFH and AO and CRO toNCO were dependent uponNRC approval of proposedchanges to the VYEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 39 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeTechnical Specifications(BVY 13-096) that replacedreferences to licensed andnon-licensed operators withreferences to CFHs andNCOs. This TechnicalSpecification change wasapproved by the NRC byletter dated December 22,2014 (ML14217A072).These staffing levels havebeen evaluated in the VYanalysis of proposed post-shutdown on-shift staffing inconjunction with thepostulated accidents thatwill be applicable in thepermanently defueledcondition.STA oversight and technicalknowledge in this functionalarea will be transferred tothe Shift Manager and/or theCRS/CFH. This transfer ofduties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing in conjunctionwith the postulatedaccidents previouslysubmitted to the NRC..Figure 8.2 VY Emergency Management Replaced figure with "VY The positions of EOFOrganization Defueled Emergency Manager and TSC Managerwill not exist in theEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 40 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeManagement Organization" Permanently Defueled ERO.Deleted the following positions: Duties and responsibilitieswill be transferred to" EOF Manager remaining positions within* TSC Manager each Emergency ResponseFacility.Figure 8.3 Technical Support Center Replaced figure with "Defueled The TSC positions identifiedEmergency Organization Technical Support Center for deletion will not exist inEmergency Organization" the Permanently DefueledDeleted the following positions: ERO. Duties andresponsibilities will be" TSC Manager transferred to remaining* TSC Communicator positions within the TSC." Mechanical Engineer* Reactor Engineer" Electrical /I&C Engineers" IT SpecialistFigure 8.4 Operations Support Center Deleted figure ERO Staffing changes resultEmergency Organization in one remaining OSCposition (OSC Manager) -Afigure is no longernecessary to describe theOSC organization.Figure 8.5 Emergency Operations Facility Replaced figure with "Defueled The EOF positions identifiedOrganization Emergency Operations Facility for deletion will not exist inOrganization" the Permanently DefueledDeleted the following positions: ERO. Duties andresponsibilities will be* EOF Manager transferred to remaining* EOF Communicator positions within the EOF.* Public Information Liaison* EOF Log Keeper* IT SpecialistEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 41 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeFigure 8.7 Joint Information Center Replaced figure with "Defueled The JIC positions identifiedOrganization Joint Information Center for deletion will not exist inOrganization" the Permanently DefueledDeleted the following positions: ERO. Duties andresponsibilities will be0 Information Coordinator transferred to remaining0 Technical Assistant positions within the JIC.0 Credentialing* Press Release Writer0 Logistics Coordinator0 Inquiry ResponseCoordinator* Media Monitoring0 JIC Log Keeper* Inquiry RespondersSection 9.2.1 -2nd 3. The Shift Technical Advisor Deleted VY will no longer be anParagraph reports to the Control Room operating nuclear powerand provides technical plant. The STA position willsupport as necessary; be eliminated.STA assignments in thisfunctional area will betransferred to the CFHposition. This transfer ofduties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing in conjunctionwith the postulatedaccidents that will beapplicable in thepermanently defueledcondition.Section 9.2.2 5. The EOF Manager 5. The Emergency Director The EOF Manager positionEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 42 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeestablishes operations in the establishes operations in the will not exist in theEOF/RC; EOF/RC; Permanently Defueled ERO.Duties and responsibilitieswill be transferred toremaining positions withinthe EOF.Section 9.2.4 -2nd 1. The Emergency Director may 1. The Emergency Director may The EOF Manager positionParagraph request that the EOF request that other personnel will not exist in theManager mobilize other be mobilized in support of Permanently Defueled ERO.personnel in support of Vermont Yankee through Duties and responsibilitiesVermont Yankee through activation of the Corporate will be transferred toactivation of the Corporate Emergency Center. remaining positions withinEmergency Center. the EOF.Section 9.3 -3r' Paragraph De-escalation from a Notification De-escalation from a Notification VY will no longer be anof Unusual Event to a recovery of Unusual Event to a recovery operating nuclear powerphase requires satisfying the phase requires satisfying the plant and emplacement orfollowing criteria: following criteria: retention of fuel into the1. Criticality controls are in 1 .Criticality controls are in reactor vessel will no longer1.eCrftecotcait cbe authorized. Therefore,effect; effect; the need for adequate core2. The core is being adequately 2. The fission product release cooling, control overcooled; has been controlled; containment pressure and3. The fission product release 3. An adequate heat transfer temperature and control ofhas been controlled; path to an ultimate heat sink reactor coolant system4. Control has been established has been established; pressure is not necessary.over containment pressure 4. Notification of Unusual Eventand temperature; conditions have been5. An adequate heat transfer reviewed, are under control,path to an ultimate heat sink and are not expected topathto n utimae hat ink deteriorate further.has been established;6. Reactor coolant systempressure is under control;EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 43 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeand/or7. Notification of Unusual Eventconditions have beenreviewed, are under control,and are not expected todeteriorate further.Table 9.1, Technical Support Emergency Plant Manager Emergency Plant Manager The TSC positions identifiedCenter; Alert or Site Area TSC Manager Maintenance Coordinator for deletion will not exist inEmergency or General (Electdcal/MechanicaVI&C) the Permanently DefueledEmergency Column Maintenance Coordinator ERO. Duties and(Electrical/MechanicaVl&C) Radiological Coordinator responsibilities will beRadiological Coordinator Engineering Coordinator(Project, transferred to remainingReactor Engineer System, Design) positions within the TSC.Engineering Coordinator(Project, Operations CoordinatorSystem, Design)Operations CoordinatorEngineering Support GroupTable 9.1, Operations OSC Manager OSC Manager VY will no longer be anSupport Center; Alert or Site Radiation Protection Staff Radiation Protection Staff operating nuclear powerArea Emergency or General plant. Use of the termEmergency Chemistry Staff Chemistry Staff "licensed" is no longerSpare Licensed Operators Spare AOs/CROs/NCOs appropriate.Spare Auxiliary Operators Control Instrument Specialists The OSC positions identifiedfor deletion will not exist inControl Instrument Specialists Plant Mechanics the Permanently DefueledPlant Mechanics ERO. Duties andresponsibilities will betransferred to remainingpositions within the OSC.Table 9.1, Emergency Emergency Director Emergency Director The EOF positions identifiedEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 44 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeOperations Facility/Recovery Offsite Communicator Offsite Communicator for deletion will not exist inCenter; Alert or Site Area Technical Advisor Technical Advisor the Permanently DefueledEmergency or General ERO. Duties andEmergency Column EOF Manager Administration and Logistics responsibilities will beAdministration and Logistics Coordinator transferred to remainingCoordinator Radiological Assessment positions within the EOF.Radiological Assessment CoordinatorCoordinator *Site/Offsite Monitoring TeamsPersonnel & Equipment Monitor*Site/Offsite Monitoring TeamsPublic Information LiaisonTable 9.1, Joint Information Company Spokesperson Company Spokesperson The JIC positions identifiedCenter; Alert or Site Area VY Public Information Staff for deletion will not exist inEmergency or General the Permanently DefueledEmergency Nuclear Public Information ERO. Duties andRepresentatives responsibilities will beJoint Information Center Staff transferred to remainingpositions within the JIC.Section 10.1.1 10.1.1 Initial offsite Radiological Dose Deleted The Unified Rascal InterfaceProjection Capability (URI) will become theVermont Yankee has developed primary site specific dosea method to quickly determine assessment software forthe projected offsite radiological Vermont Yankee. Thisconditions at various distances computer program replacesdownwind of the plant site. the existing ODPS andDuring the initial stages of an METPAC dose assessmentemergency, the Shift Manager or software.designated individual isresponsible to perform the initialevaluation of offsite radiologicalconditions. The initial evaluationEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 45 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeof offsite radiological conditionsis accomplished by utilizing theOffsite Dose Projection System(ODPS).The ODPS utilizes a straight lineGaussian plume dispersionmodel programmed on the plantprocess computer. The programallows the user the option toselect one of two releasepathways (elevated or ground)and to utilize site-specificradiological and meteorologicalinformation to estimate the TotalEffective Dose Equivalent andadult thyroid Committed DoseEquivalent (elevated releaseonly) at a distance of 0.35 milesto 10 miles from the plant site.Section 10.1.2Once the EOF/RC is activated, VermontYankee utilizes a plume tracking/doseprojection system, which is capable ofproviding near real time offsite doseestimated for actual meteorologicaland radiological accident conditions.The system assumes a Gaussian,variable trajectory, plume segmenttransport model designed to handle thesite-specific atmospheric dispersioncharacteristics associated with theVermont Yankee Nuclear Power Stationsite. Both continuous and intermittentreleases for either ground or stackrelease points can be evaluated. Theeffects of release height, building wakeVermont Yankee utilizes a plumetracking/dose projection system, whichis capable of providing near real timeoffsite dose estimated for actualmeteorological and radiologicalaccident conditions. The systemassumes a variable trajectory, plumesegment transport model designed tohandle the site-specific atmosphericdispersion characteristics associatedwith the Vermont Yankee NuclearPower Station site. Both continuousand intermittent releases for eitherground or stack release points can beevaluated. The effects of releaseheight, buildinR wake entrainment,The Unified Rascal Interface(URI) will become theprimary site specific doseassessment software forVermont Yankee. Thiscomputer program replacesthe existing ODPS andMETPAC dose assessmentsoftware. This section isrevised to describe URI.v -vEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 46 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeentrainment, momentum plume rise,precipitation and terrain height can beassessed in the evaluation. Plumetrajectories are based on onsitemeteorological tower information andtopography of the Connecticut RiverValley.The model combines complex plumetransport algorithms with the samedose assessment algorithms used bythe model described in Section 10.1.1.The model is programmed on apersonal computer. The program isdesigned to graphically display thecalculated plume characteristics on a10-mile Vermont Yankee EPZ site mapwhile providing transcripts of alldispersion and dose calculations.rally, the Offsite Dose Nomogram can beused to determine an activity releaserate (l.Ci/sec) and a projected offsitewhole body plume centerline dose rate(mR/hr) at 1/3 of a mile from the stack.These determinations are made byusing Figure 10.1 with the followingadditional information:after reactor shutdown;ilant stack high range monitor response;ilant stack flow rate at the time of theaccident; andspeed.The assumptions incorporated in andthe use of the nomograms contained inmomentum plume rise, precipitationand terrain height can be assessed inthe evaluation. Plume trajectories arebased on onsite meteorological towerinformation and topography of theConnecticut River Valley.The model combines complex plumetransport algorithms with doseassessment algorithms. The model isprogrammed on a personal computer.The program is designed to graphicallydisplay the calculated plumecharacteristics on a 10-mile VermontYankee EPZ site map while providingtranscripts of all dispersion and dosecalculations.EN-LI-I00 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 47 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeFigure 10.1 is discussed in Appendix C.Section 10.2 -1st Paragraph In the event a General In the event a General VY will no longer be anEmergency has been declared, Emergency has been declared, operating nuclear powerVermont Yankee immediately Vermont Yankee immediately plant and emplacement orrecommends protective actions recommends protective actions retention of fuel into theto state authorities based on to state authorities based on reactor vessel will no longerplant conditions which include plant conditions. At a minimum, be authorized. Therefore,the status of core and the Shift Manager or Emergency the need to communicatecontainment conditions. At a Director, who is in charge of the the status of the core andminimum, the Shift Manager or emergency response activities, containment conditions isEmergency Director, who is in recommends that the general not necessary.charge of the emergency public be advised to seek shelterresponse activities, recommends for the towns of Hinsdale, Newthat the general public be Hampshire and Vernon,advised to seek shelter for the Vermont; and the towns locatedtowns of Hinsdale, New five miles downwind in theHampshire and Vernon, affected sectors.Vermont; and the towns locatedfive miles downwind in theaffected sectors.Section 10.2 -2nd Paragraph If plant conditions indicate a If plant conditions indicate a VY will no longer be ansevere reactor accident exists severe accident exists, Vermont operating nuclear powerinvolving actual or projected Yankee recommends to the plant and emplacement orsubstantial core damage, appropriate state officials retention of fuel into theVermont Yankee recommends to evacuation of the towns of reactor vessel will no longerthe appropriate state officials Hinsdale, New Hampshire and be authorized. Therefore, anevacuation of the towns of Vernon, Vermont; and all towns accident involving theHinsdale, New Hampshire and located five miles downwind in reactor the potential forVernon, Vermont; and all towns the affected sectors. actual or projectedlocated five miles downwind in substantial core damage nothe affected sectors. longer exists.Section 10.3- 2nd Paragraph Table 10.2 specifies the Table 10.2 specifies the VY will no longer be anguidelines on emergency dose guidelines on emergency dose operating nuclear powerlimits for personnel providing limits for personnel providing plant. The on-shiftEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 48 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeemergency response duties emergency response duties Chemistry Technicianwhich is consistent with the which is consistent with the positions will be eliminated.Environmental Protection Environmental ProtectionAgency Emergency Worker Agency Emergency WorkerDose Limit Guides (EPA Dose Limit Guides (EPA400-R-92-001). The Shift 400-R-92-001). The ShiftManager initially has the Manager initially has theresponsibility to authorize responsibility to authorizeemergency dose commitments emergency dose commitmentsuntil relieved by the Emergency until relieved by the EmergencyPlant Manager. This Plant Manager. Thisauthorization is coordinated with authorization is coordinated withthe assistance of the the assistance of theRadiological Coordinator or Shift Radiological Coordinator andChemistry and Radiation Radiation Protection TechniciansProtection Technicians as as needed. Exposure toneeded. Exposure to individuals individuals providing emergencyproviding emergency functions functions will be consistent withwill be consistent with the limits the limits specified in Table 10.2specified in Table 10.2 with with every attempt made to keepevery attempt made to keep exposures ALARA.exposures ALARA.Section 10.5.1 Medical Response Team Medical response is provided by The Medical Responsemembers are trained in on-shift Fire Brigade members Team is being eliminated.accordance with station trained in basic first-aid and Medical response will beprocedures. Cardiopulmonary resuscitation provided by Fire Brigade(CPR). members available on siteon a 24-hour per day basis.Section 10.6 A range of protective actions to A range of protective actions to Revised to reflect importantprotect onsite personnel during protect onsite personnel during equipment duringhostile action is provided to hostile action is provided to permanently shutdown andensure the continued ability to ensure the continued ability to defueled plant condition.safely shut down the reactor and maintain equipment important toperform the functions of the the safe storage of spent fuelEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 49 OF 52Emergency Plan Section Before (Rev. 54) After Reason for Changeemergency plan. and perform the functions of theemergency plan.Figure 10.1 Figure 10.1 Vermont Yankee Deleted Figure VY will no longer be anEmergency Dose Rate operating nuclear powerNomogram plant. Figure 10.1 is nolonger applicable because itis based on the isotopic mixfor a LOCA.Section 11.3 -4th Paragraph The Public Information Liaison The Technical Advisor and The Technical Advisor willand required staff report to the required staff report to the assume this duty in theEOF/RC for coordinating the EOF/RC for coordinating the permanently defueledaccident information between the accident information between the condition.plant and the Joint Information plant and the Joint InformationCenter. Center.Section 11.3- 6h Paragraph Normally, a prerecorded Normally, a prerecorded VY will no longer be anmessage provides, on a daily message provides, on a daily operating nuclear powerbasis, routine operating basis, routine plant information, plant.information, changes in plant changes in plant conditions, andoperation, 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 ResponseDrills 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 Brigademedical drill is conducted medical drill is conducted members available on siteannually 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 toemergency equipment is emergency equipment is procedure number.provided in OP 3506, provided in OP-EQUIP-3506,"Emergency Equipment "Emergency EquipmentReadiness Check") Readiness Check")EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 50 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeAppendix C Appendix C Initial Offsite Dose Appendix deleted in its entirety VY will no longer be anRate Estimation operating nuclear powerplant. Appendix C is nolonger applicable because itis based on the isotopic mixfor a Loss of CoolantAccident (LOCA).Appendix G -Section I OP-3507 EPOP-EREC-3507 Editorial revision toOP-3508 EPOP-MED-3508 procedure numbers.OP-3510 EPOP-OSMT-3510OP-3513 EPOP-RAD-3513OP-3547 EPOP-SEC-3547OP-3548 EPOP-TERM-3548AP-3712 EPAP-TRNG-3712Appendix G -Section I Not Applicable Add: See below.V-EN-FAP-EP-009, Use of KI forthe Emergency ResponseOrganizationV-EN-FAP-EP-010, SevereWeather ResponseV-EN-FAP-EP-012, SevereWeather RecoveryV-EN-EP-202, EquipmentImportant to EmergencyPreparednessV-EN-EP-301, EmergencyPlanning Assessment of OffsiteEmergency Response CapabilityEN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 51 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeFollowing a Natural DisasterV-EN-EP-305, EmergencyPlanning 10CFR50.54(q) ReviewProgramV-EN-EP-306, Drills andExercisesV-EN-EP-307, Hostile ActionBased Drills & ExercisesV-EN-EP-308, EmergencyPlanning CritiquesV-EN-EP-310, EmergencyResponse OrganizationNotification SystemV-EN-EP-401, Public Use ofEmergency PreparednessOwner Controlled AreaV-EN-EP-601, CorporateEmergency Center OperationsV- EN-EP-801 -EmergencyResponse OrganizationAppendix G -Section I Not Applicable Add: EPOP-AFA-10083 wasEPOP-AFA-10083 -Alternative developed and added to theEPciyAciatn Emergency Plan forFacilityi Activation compliance with 10 CFREPOP-URI-10095- Offsite Dose Part 50, Appendix E SectionAssessment using the Unified IV.E.8.d.Rascal Interface EPOP-URI-1 0095 wasdeveloped and added to theEmergency Plan to addressthe change to URI.EN-LI-100 REV. 16 ATTACHMENT 9.1 PROCESS APPLICABILITY DETERMINATION FORMPAGE 52 OF 52Emergency Plan Section Before (Rev. 54) After Reason for ChangeAppendix G -CorporateSupport ProceduresCorDorate SUDDort Procedures I Deletedl l lEN-EP-311 will be deleted.VY will no longer be anoperating nuclear powerplant.Section VI.1 ofAppendix E to 10 CFR Part50 indicates that ERDS isnot applicable to nuclearpower facilities that are shutdown. Based on thepermanently defueledstatus, this system is nolonger necessary to transmitsafety system parameterdata to the NRC.The applicable informationfrom the remainingprocedures will be relocatedto a VY-specific procedureand added to the EPIP list(see above) and theCorporate Support Sectionof Appendix G will bedeleted.EN-EP-309 and EN-EP-606will be deleted as neitherprocedure is applicable toVY. These proceduresshould not have beenincluded in the VYEmergency Plan andremoval is an editorialchange.EN-LI-100 REV. 16 A'n'ACHMENT 9.1IOCFR50.64(q) SCREENINGProcedure/Document Number. Emergency Plan Revision: 55Page 1 of 10Equipment/Facility/Other. Vermont YankeeTitle: Vermont Yankee Emergency PlanPart I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a changeto 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 ContentsSection 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 ActionSection 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 7Section 4.1. The Site* Revised the 2e Paragraph to address January 12, 2015 certification of permanent cessation of operations andpermanent removal of fuel from the reactor vesselSection 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 layoutFlours 6.3. Ooerational Sucoort Center Layout* Replaced figure with figure accurately depicting OSC layoutFioure 6.4. Emeroencv Ooerations Facilitv/Recoverv Center LaYout0 Replaced figure with figure accurately depicting EOF/RC layoutSection 7.3. Utility Microwave and Radio Systems* Removed, "The Utility Microwave Is a line of sight dedicated system used to notify system load dispatchers ofemergency conditions at the plant. The telephone has buttons marked for each load dispatcher. By pushing oneof 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 dispatchershave 24-hour manning capability at their organizations. The systems are tested once a week with bothorganizations."EN-EP-305 REV 3 AI"rACHMENT 9.1IOCFR50.54(q) SCREENINGATTACHMENT .1110F55(a CENNSProcedure/Document Number: Emergency Plan Revision: 55Page 2 of 10EquipmentlFacillty/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanSection 7.10. EmemencW Resoonse Data System (Deletion addressed in seoarate 50.54(a) screenino and analvsisla Deleted SectionTable 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 KeySection 8.2. Emergency Response Oeanilzation* Changed "onshit" to "on-shift"* Deleted "Plant trip" bulletSection 8.2.10. Decision Maker* Replaced "the senior licensed individual In the TSC will assume the role of Decision Maker as defined in theSAM Guideline" with "the Operations Coordinator In the TSC will assume the role of Decision Maker as definedin 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 Cardiopulmonaryresuscitation (CPR)."Section 10.1.1. Initial Offsfte RadloloaicaL Dose Proiection Caoabilitv* Deleted SectionSection 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 paragraphSection 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 figureSection 11.3. Public Information* Replaced, "routine operating Information, changes in plant operation" with "routine plant Information, changes inplant conditions"Section 12.1.4. Medical Drill0 Replaced, "To evaluate the training of the facility's medical response team and offsite..." with "To evaluate thetraining of the facility's medical response and offslte..."Appendix B. Ememencv Eouiomenta Changed procedure number from "OP 3506" to "EPOP-EQUIP-3506"Aooendix C. Initial Offsite Dose Rate Estimation* Deleted AppendixEN-EP-305 REV 3 AI~rAciwENT 9.110CFR50.54(q) SCREENINGProcedure/Document Number: Emergency Plan Revision: 55Page 3 of 10EquipmentlFacilltylOther: Vermont YankeeTitle: Vermont Yankee Emergency PlanAcoendlx 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 complywith 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 tothe 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 RecoveryV-EN-EP-202, Equipment Important to Emergency Preparedness* V-EN-EP-301, Emergency Planning Assessment of Oftsite Emergency Response Capability Following aNatural 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 FluResponse from Section II, Support Plans, Corporate Support Procedures" Deleted Section II, Support Plans, Corporate Support ProceduresReferences 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-CertifiedOperators (NCOs). Specifically, Section 8.1, Table 8.4, and Figures 6.3 and 8.1. Emergency Plan changessubmitted in BVY 14-018 stated, "Title changes for the CRS and CRO/AC to CFH and NCO, respectively, aredependent upon NRC approval of proposed changes to the VY Technical Specifications (BW 13-098) thatrevise the minimum shift staffing requirements in the VY Technical Specifications by replacing references tolicensed and non-licensed operators with references to CFHs and NCOs. The Emergency Plan submitted inBVY 14-018 addressed the pending title changes by referring to titles as "CR5/CFi" and AO/CROINCO" andincluded Note .... In Table 8.4 Indicating title changes were dependent on NRC approval of BVY 13-096. ThisTechnical Specification change was approved by the NRC by letter dated December 22, 2014 (ML14217A072).EN-EP-305 REV 3 ATTACHMENT 9.110CFR50-54(Q) SCREENINGProcedure/Document Number-. Emergency Plan I elslon: 55Page 4 of 10 eEqulpment/Facillty/Other Vermont YankeeTitle: Vermont Yankee Emergency PlanPart II. Activity Previously Reviewed? ElYES 0 NOIs this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.64(q)(3) Continue toEvaluation Is next partAlert and Notification System Design Report? NOT required.EnterIf YES, Identify bounding source document number/approval reference and justmfcatlonensure the basis for concluding the source document fully bounds the proposed bel andchange is documented below: complete PartVl.Justification:[0 Bounding document attached (optional)Part Ill. Applicability of Other Regulatory Change Control ProcessesCheck 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 toother documents which have a different change control process and are NOT to be included in this 50.54(q)(3)Screening.APPLICABILITY CONCLUSION0 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 theemergency plan or affects the implementation of the emergency plan: continue the 50.54(q)(3) Screening for that portionof 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 PROCESSES10 CFR 50.54(q)Part IV. Editorial Change [:]YES ONO50.54(qX3) Continue to nextIs this activity an editorial or typographical change such as formatting, paragraph Evaluation is patnumbering, spelling, or punctuation that does not change intent? NOT required.Justification: Enejustification andcomplete PanA 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 IPart V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standardfunction identified in brackets) Does this activity affect any of the following, Including program elements fromNUREG-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. (113. 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] Q15. 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] " 08. 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 9.110CFR60.54(q) SCREENINGSProcedure/Document Number: Emergency Plan Revision: 55Page 5 of 10EquipmentlFacllltylOther. Vermont YankeeTitle: Vermont Yankee Emergency Planup notifications. [5)9. Administrative and physical means have been established for alerting and providing promptInstructions 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 ElNotification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANSdesign report and supporting FEMA approval letter. [5]11. Systems are established for prompt communication among principal emergency responseorganizations. [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 theplume exposure pathway emergency planning zone (EPZ). [7]14. Coordinated dissemination of public Information during emergencies Is established. [7] U15. Adequate facilities are maintained to support emergency response. (8]18. Adequate equipment is maintained to support emergency response. [8] El17. 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 areavailable to support the formulation of PARs and have been provided to State and localgovernmental authorities. (10120. A range of protective actions is available for plant emergency workers during emergencies, Includingthose for hostile action events.[1 0]21. The resources for controlling radiological exposures for emergency workers are established. [111122. Arrangements are made for medical services for contaminated, Injured individuals. [12]23. Plans for recovery and reentry are developed. [13] L124. A drill and exercise program (including radiological, medical, health physics and other programareas) Is established. [14125. 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 Identifyweaknesses. [14]28. Identified weaknesses are corrected. [14] U27. 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 CONCLUSION0 If no Part V criteria are checked, a 50.54(q)(3) Evaluation Is NOT required; document the basis for conclusion belowand complete Part VI.I if any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.BASIS FOR CONCLUSIONEditorial ChanagesThe following editorial changes require no further evaluation.The Table of Contents has been revised to address updated page numbers and the deletion of Section 7.10EN-EP-305 REV 3 ATTrACHMENT 9.110CFRSO.54(a) SCREENINGProcedure/Document Number: Emergency Plan /Rvision: 55Page 6 of 10 EEqulpment/FacilltyiOther: Vermont YankeeTitle: 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 RateEstimation). These changes do not change the meaning or Intent of the Emergency Plan, change anyfacilities or equipment, or change any of the processes described in the Emergency Plan. Updates to theTable of Contents to match the body of the Emergency Plan are administrative in nature and no furtherevaluation is required.Changes to the definitions of Alert, General Emergency, Notification of Unusual Event, Site Area Emergencyand 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 definitionswith those In NEI 99-01, "Methodology for Development of Emergency Action Levels," Rev. 5; on which theVY 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 furtherevaluation Is required.The change to Item 7 In Section 3.2 is an editorial change. The Emergency Notification System Is a formalsystem used to notify the NRC during an emergency. The generic use of "emergency notification system" inStep 7 can be confusing and Is meant only to direct the communicator to use the notification plan set forth inFigure 9.1 and Table 9.1 of the Emergency Plan and not the Emergency Notification System. Figure 9.1 isentitled "Notification Plan" and identifies the methods used to notify various offsite agencies. No furtherevaluation 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 furtherevaluation 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. Thisrevision 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 theremainder 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 assumingthe role of Decision Maker during implementation of Severe Accident Management (SAM). Section 2.3 ofAttachment 3 (Operations Coordinator) of EPOP-TSC-3542 instructs the Operations Coordinator in the TSCto assume the duty of the SAM Decision Maker if it is determined that the emergency requiresimplementation of SAM. Revision of the Emergency Plan to refer to the Operations Coordinator in the TSCand to plant procedures rather than the senior licensed individual in the TSC and the SAM Guideline iseditorial 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 updateprocedure number OP 3506 to EPOP-EQUIP-3506 does not impact any of the 10 CFR 50.47(b) planningstandard functions or program elements listed in Part V of this form. Reference to these documents isadministrative In nature and no further evaluation is required.Appendix G: The revisions to Appendix G, "Index of Emergency Plan Implementing Procedures andSupport Plans," of the Site Emergency Plan to document relocation of VY-specific Information fromCorporate Procedures in Section II to VY-speclfic procedures in Section I does not Impact any of the 10 CFR50.47(b) planning standard functions or program elements listed in Part V of this form. Additionally, theaddition of new procedure EPOP-AFA-10083, Alternative Facility Activation, was added to the EmergencyPlan 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 notapplicable to VY. These procedures should have not been included in the VY emergency plan and removalis an editorial change. New procedure EPOP-URI-1 0095, Offshe Dose Assessment using the Unified RascalInterface, 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. APEN-EP-305 REV 3 ATTACHMENT 9.11 0CFR60.54(q) SCREENINGATICMNT91IIIII05(a SRENNProcedure/Document Number: Emergency Plan -_ Revision: 55Page 7 of 10Equipment/Facililty/Other: Vermont YankeeTitle: Vermont Yankee Emergency Plan3712 to EPAP-TRNG-3712 does not impact any of the 10 CFR 50.47(b) planning standard functions orprogram elements listed In Part V of this form. The changes are administrative in nature and no furtherevaluation Is required.Non-Editorial Chances Not AffectIna Proaram Elements Associated with an Emernencv PlanningFunctionThe following non-editorial changes do not affect program elements associated with an emergency planningfunction and no further evaluation is necessary.Section 3.2, Actions In an Emergency, Item 5: The addition of the InForm Notification System as theprimary method of performing off-site emergency notifications was evaluated in a 50.54(q) evaluationconducted In December 2013, prior to implementation of Rev. 54 of the Emergency Plan. InForm utilizessource and destination computers that communicate via the Internet to send emergency notifications to thestates 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 bemade using the Emergency Notification System rather than the Nuclear Alert System. The EmergencyNotification System is used to notify the NRC during an emergency. This revision changes "EmergencyNotification System" to "InForm Notification System" to accurately reflect that notifications to the three statesare made using InForm as evaluated In the previous 50.54(q) conducted in December 2013. This revisiondoes not change any facilities or equipment or change any of the processes used to make emergencynotifications. The change does not affect program elements associated with the emergency planningfunctions and no further evaluation is necessary.Section 5.1, Notfifcation of Unusual Event: This section of the Emergency Plan was revised to removethe reference to changes In operational status when a Notification of Unusual Event is declared. OnSeptember 23,2013, ENO informed the NRC that VY will permanently cease operations at the end of thecurrent operating cycle, which Is expected to occur in the fourth quarter of 2014. Upon docketing of thecertifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuelfrom the reactor vessel (10 CFR 50.82(a)(1)(0i)). pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licensefor VY will no longer authorize operation of the reactor or emplacement or retention of fuel Into the reactorvessel. Because VY will no longer be authorized to operate the reactor or place fuel within the reactorvessel, changes in operational status are no longer possible and references to operational status can beremoved from the Emergency Plan. This revision does not change any facilities or equipment or change anyof the processes described In the Emergency Plan. The change does not affect program elementsassociated 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 toremove the discussion of notifying load dispatchers of emergency conditions at the plant. According toSection 10.18.3 of the UFSAR, Rev. 26, the microwave system provides for the Interchange of Informationon electrical generation and transmission between the station and the electrical dispatcher. This systemallows the transfer of yard switching information, power level monitoring information and voice contactbetween the station main control and the electrical system dispatching offices. Upon docketing of thecertifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuelfrom the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licensefor VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactorvessel. Because VY will no longer be authorized to operate the reactor or place fuel within the reactorvessel, potential disruptions to the electrical grid due to an emergency condition at VY are no longerpossible. As a result, the need to contact load dispatchers in the event of an emergency at VY no longerexists. The Microwave System will remain in place and serve as a backup means to provide updates of plantconditions to NRC Region I If the commercial telephone system fails. This revision does not change anyfacilities or equipment or change any of the processes described in the Emergency Plan. The change doesnot affect program elements associated with the emergency planning functions and no further evaluation isnecessary.Table 7.1. Vermont Yankee Emeraencv Communications Matrix: The addition of the InForm NotificationEN-EP-305 REV 3 ATTACHMENT 9.110CFR50.54(q) SCREEMNOSProcedure/Document Number: Emergency Plan Revision: 55Page 8 of 10Equipment/Facillty/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanSystem 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. InFormutilizes source and destination computers that communicate via the internet to send emergency notificationsto the states of Vermont, New Hampshire and Massachusetts during declared emergencies anddrilis/exercises. The Emergency Notification System is used to notify the NRC during an emergency. Thisrevision adds InForm as "11" in Table 7.1 to accurately reflect that communications with the three statesinclude using InForm as evaluated in the previous 50.54(q) conducted in December 2013. This revision doesnot change any facilities or equipment or change any of the processes used to make emergencynotifications. The change is administrative in nature, does not affect program elements associated with theemergency planning functions and no further evaluation is necessary.References to Control Room Supervisor (CRS), Control Room Operator (CRO), and AuxiliaryOperators (AO): Throughout the Emergency Plan, references to Control Room Supervisor (CRS), ControlRoom 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, andFigures 6.3 and 8.1. Emergency Plan changes submitted In BVY 14-018 stated, "Title changes for the CRSand CRO/AO to CFH and NCO, respectively, are dependent upon NRC approval of proposed changes tothe VY Technical Specifications (BVY 13-096) that revise the minimum shift staffing requirements in the VYTechnical Specifications by replacing references to licensed and non-licensed operators with references toCFHs and NCOs. The Emergency Plan submitted in BVY 14-018 addressed the pending title changes byreferring to titles as "CRS/CFH" and AO/CROINCO" and included Note i**" In Table 8.4 Indicating titlechanges were dependent on NRC approval of BVY 13-096. This Technical Specification change wasapproved by the NRC by letter dated December 22, 2014 (ML1 4217A072). The elim ination of CRS, CROand AO titles and replacement with CFH and NCO Is editorial in nature and no further evaluation is requiredwith respect to this change.Figure 10.1, Vermont Yankee Emergency Dose Rate Nomogram: Figure 10.1 was deleted. Upondocketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanentremoval of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFRPart 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuelinto the reactor vessel. Figure 10.1 is based on the isotopic mix for a LOCA. Because VY will no longer beauthorized to operate the reactor or place fuel within the reactor vessel, a LOCA is no longer possible. Thisrevision does not change any facilities or equipment or change any of the processes described in theEmergency Plan. The change does not affect program elements associated with the emergency planningfunctions 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 ofthe certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(1)) and permanent removal offuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel Into thereactor vessel. Because VY will no longer be authorized to operate the reactor or place fuel within thereactor vessel, providing "operating information or changes in plant operation Is not possible. This revisiondoes not change any facilities or equipment or change any of the processes described in the EmergencyPlan. The change does not affect program elements associated with the emergency planning functions andno further evaluation is necessary.Appendix C, Initial Offaite Dose Rate Estimation: Appendix C was deleted. Upon docketing of thecertifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuelfrom the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licensefor VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactorvessel. Appendix C is based on the isotopic mix for a LOCA. Because VY will no longer be authorized tooperate the reactor or place fuel within the reactor vessel, a LOCA is no longer possible. This revision doesnot chance any facilities or eauilpment or chanae anv of the arocesses described in the Emeraencv Plan.EN-EP-305 REV 3 AI~rAcHMENT 9.1IOCFRSO.54(q) SCREENINGProcedure/Document Number. Emergency Plan Revision: 55Page 9 of 10EqulpmentIFeclllty/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanThe change does not affect program elements associated with the emergency planning functions and nofurther evaluation is necessary.Section 8.2, Emergency Response Organization: This section was revised to delete the bullet, "Planttrip." Upon docketing of the certifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) andpermanent 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 orretention of fuel into the reactor vessel. Because VY will no longer be authorized to operate the reactor orplace fuel within the reactor vessel, a plant trip is no longer possible. This revision does not change anyfacilities or equipment or change any of the processes described in the Emergency Plan. The change doesnot affect program elements associated with the emergency planning functions and no further evaluation isnecessary.Section 10.6, Protective Actions for Onalst Personnel: This section was revised to replace, "safely shutdown the reactor" with "maintain equipment Important to safe storage of spent fuel." Upon docketing of thecertifications for permanent cessation of operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuelfrom the reactor vessel (10 CFR 50.82(a)(1)(11)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licensefor VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactorvessel. Because shutting down the reactor is no longer necessary and the focus Is on maintaining SFPcooling. This revision does not change any facilities or equipment or change any of the processes describedin the Emergency Plan. The change does not affect program elements associated with the emergencyplanning functions and no further evaluation Is necessary.Non-Editorial Chanage Affecting Proaram Elements Associated with an Emermencv PlannlnaFuntlionThe remaining changes to Section 7.10 (Emergency Response Data System), Section 10.5.1 (MedicalTreatment), Section 10.1.1 (Initial Offslte Radiological Dose Projection Capability), Section 10.1.2 (VariableTrajectory Atmospheric DlspersionlDose Projection Capability), Section 12.1.4 (Medical Drill) and AppendixG (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 changesare associated with the elimination of the reference to the Medical Response Team and replacement of theexisting Offsite Dose Projection System (ODPS) and METPAC dose assessment software with the UnifiedRascal Interface (URI). URI will become the primary site specific dose assessment software for VermontYankee. A 10 CFR 50.54(q) Evaluation will be performed to determine whether the changes result in areduction 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 areduction in effectiveness of the Emergency Plan requiring prior NRC approval. If the 50.54(q) analysisdetermines the elimination of ERDS is not a reduction in effectiveness of the VY Emergency Plan, thesubsequent elimination of EN-EP-311 Is administrative in nature and no further evaluation is necessary.EN-EP-305 REV 3 AIrrACHMENT 9.1IOCFR50.54(q) SCREENINGProcedure/Document Number:. Emergency Plan Revision: 55Page 10 of 10EquipmentiFacility/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanPart 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 Swdon1-27-2015Nuclear EP Project Manager ..,vr.Approver Name (Print) Approver Signature DateMike McKenneyEP manager or designee //Z7/513EN-EP-305 REV 3 ATTACHMENT 9.2 1 OCFR5O.54(q) EVALUATIONATTACHMENT 9.2 10CFRS0.54(q) EVALUATIONSHEET 1 OF 8Procedure/Document Number. Emergency Plan I Revision: 55Equipment/Facility/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanPart I. Description of Proposed Change:The VY Emergency Plan is being revised to eliminate reference to the Medical Response Team and to replace theexisting Offaite Dose Projection System (DOPS) and METPAC dose assessment software with the Unified RascalInterface (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 proposedelimination of the Medical Response Team:Section 10.5.1- Medical TreatmentReplaced, "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 Cardiopulmonaryresuscitation (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 replacementof ODPS and METPAC with URI:Section 10.1.1. Initial Offsite Radioloalcal Dose Prolection Caoabilltv* Deleted SectionSection 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 paragraphPart I1. Description and Review of Licensing Basis Affected by the Proposed Change:Medical Resnonse TeamThe UFSAR (Rev. 26), Technical Specifications (Rev. 271), Technical Requirements Manual (TRM) (Rev. 53) andOffsIte Dose Calculation Manual (ODCM) (Rev. 35) were reviewed as part of this analysis. The documents weresearched for the following keywords:a Medical and Medical ResponseAdditionally, the Licensing Research System (LRS) and the Emergency Plan (Rev. 53 and Rev. 54) were searched forrelevant Information using the same keywords Identified above and no relevant results were found.The following summarizes the findings of the review.UFSAR (Rev, 201The UFSAR contains no references to medical response or the Medical Response Team.Technical Specifications (Rev. 2711The 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) EVALUATIONSHEET 2 OF 8Procedure/Document Number: Emergency Plan I Revision: 55EquipmentlFacility/Other: Vermont Yankee ITitle: Vermont Yankee Emergency PlanEmergencv Plan 1Rev. 53 and 541Section 10.5.1 states that Medical Response Team members are trained In accordance with station procedures. Section12.1.4 states that to evaluate the training of the medical response team and offsite medical response (ambulance andhospital), a medical drill Is conducted annually with a simulated contaminated Injured Individual.Unified Rascal InterfaceThe method used to perform dose assessment is discussed In Section 10 of the Emergency Plan and the EmergencyPlan 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 foritems relating to the keywords METPAC, ODPS, and dose assessment. BVY 13-059, "Commitment for Implementationof Multi-source Dose Assessment Capablityw, was found. URI meets this commitment by providing an automatedmethod for performing a multi-source dose consequences analysis.Part Ill. Describe How the Proposed Change Complies with Relevant Emergency PreparednessRegulatlon(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 NRCcommitments (LRS) was searched as described In Part 1i and the results are described in Part II, above.Applicable Regulations:Medical Response Teem10 CFR 5$47(bX1) -Assignment of Responallblify/Organizational Control: Primary responsibilities for emergencyresponse by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zoneshave been assigned, the emergency responsibilities of the various supporting organizations have been specificallyestablished and each principal response organization has staff to respond and to augment Its initial response on acontinuous basis.10 CFR 50.47(bX2) -Onaite Emergency Organization: On-shift facility licenses responsibilities for emergencyresponse are unambiguously defined, adequate staffing to provide initial facility accident response In key functionalareas is maintained at all times, timely augmentation of response capabilities Is available and the Interfaces amongvarious 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 emergenciesshall be described, including definition of authorities, responsibilties, and duties of individuals assigned to the licensee'semergency organization and the means for notification of such individuals in the event of an emergency. Specifically, thefollowing 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 ofa. 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 theexchange of Information with offsete authorities responsible for coordinating and Implementing offsite emergencymeasures.3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent tothe 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 beresponsible for making offsite dose projections, and a description of how these projections will be made and the resultstransmitted 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 qualificationsfor coping with emergency conditions that may arise. Other persons with special qualifications, such as consultantsA whoare 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) EVALUATiONSHEET 3 OF 8Procedure/Document Number. Emergency Plan I Revision: 55Equipment/FacilltyIOther: Vermont YankeeTitle: Vermont Yankee Emergency Plan6. 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, andFederal agencies with responsibilities for coping with emergencies. Including hostile action at the site. For purposes ofthis appendix, 'hostile action Is defined as an act directed toward a nuclear power plant or its personnel that Includesthe use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. ThisIncludes attack by air, land, or water using guns, explosives projectiles, vehicles, or other devices used to deliverdestructive force.8. Identification of the State and/or local officials responsible for planning for, ordering, and controllng appropriateprotective actions, including evacuations when necessary.9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnelassigned emergency plan Implementation functions are not assigned responsibilities that would prevent the timelyperformance 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 contaminatedInjured IndMduals.10 CFR 50.47(bX14) -Drill and Exercises: Periodic exercises are (will be) conducted to evaluate major portions ofemergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, anddeficiencies 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 tothose 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 shallbe 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 treatmentfacilities outside the site boundary;7. Arrangements for treatment of Individuals injured in support of licensed activities on the site at treatment facilitiesoutside 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 toensure that employees of the licensee are fanillar with their specific emergency response duties, and (b) Theparticipation in the training and drills by other persons whose assistance may be needed In the event of a radiologicalemergency shall be described. This shall Include a description of specialized Initial training and periodic retrainingprograms to be provided to each of the following categories of emergency personnel:vi. Arat AId and rescue teamsvii. Medical support personnel2. The plan shall describe provisions for the conduct of emergency preparedness exercises as follows: Exercises shalltest the adequacy of timing and content of implementing procedures and methods, test emergency equipment andcommunications networks, test the public alert and notification system, and ensure that emergency organizationpersonnel are familiar with their duties.Site Compliance: a licensee organizational description, staffing levels and assignment of responsibilities required by10 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. TheEmergency Response Organization (ERO) Is described In Section 8.2 of the VY Emergency Plan. In Table 8.4, first aidresponsibilities 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 theVermont Yankee Emergency Plan (BVY 14-018). developed In accordance with NEI 10-05, "Assessment of On-ShiftEmergency Response Organization Staffing and Capabilities" (NEI 10-05), do not consider the Medical Response TeamIn the analyses because the Medical Response Team is not onsite on a 24-hour per day basis. In accordance with NEIEN-EP-305 REV 3 ATTACHMENT 9.2 1 OCFR50.54(q) EVALUATIONSHEET 4 OF 8Procedure/Document Number: Emergency Plan Revision: 55Equipment/Facility/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanI. q10-05 section 2.6. the analyses included a review of rescue operations and first aid response, although neither task wasrequired during the evaluated scenarios. Additionally, the analyses state that the station fire brigade staff Is trained Infirst aid and rescue operations and is available to perform these tasks It required, on a 24-hour per day basis. First aidand 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 Isdelineated 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, Isdelineated in Sections 10.5 and 12.1.4. Section 10.5.1 states that Medical Response Team members are trained inaccordance with station procedures. Section 10.5.2 addresses arrangements to transport contaminated InjuredIndividuals offsite for treatment. Section 12.1.4 states that to evaluate the training of the medical response team andoffsite medical response (ambulance and hospital), a medical drill is conducted annually with a simulated contaminatedinjured Individual.The emergency plan and Its implementing procedures will continue to assign responsibilities for medical response. Withrespect to training lor medical support personnel, the requirement for medical response personnel to successfullycomplete an EMT Course exceeds the guidance contained in NUREG.0654-FEMA-REP-1, "Criteria for Preparation andEvaluation 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 andrequirements. Because the training provided for medical response personnel will continue to meet or exceed the RedCross Multi-Media training Identified in NUREG.0654 Planning Standard 0, Evaluation Criteria 3, the proposed changesto eliminate the requirement for medical response personnel to complete an EMT course and the subsequent changes toSections 10.5.1 and 12.1.4 of the VY Emergency Pian continue to comply with the VY Emergency Plan, TechnicalSpecifications and applicable regulations.Unified Rascal Interface10 CFR 50.47(b)(4) -Emergency Classification System: A standard emergency classification and action levelscheme, the bases of which Include facility system and effluent parameters, is/ In use by the nuclear facility licensee, andState and local response plans call for reliance on Information provided by facility licensees for determinations ofminimum initial offsite response measures.Site Comoliance: URI, like METPAC/ODPS, is a dose assessment tool which can be used to determine if anyEmergency Action Levels (EALs) have been reached or exceeded. The two Vermont Yankee EALs that are tied to doseassessment are AG1.2 and AS1.2. The EAL thresholds are based on exceeding the EPA PAGe or 10% of the EPAPAGs, respectively, at or beyond the site boundary. The EALs do not delineate the method for determining thecalculated dose to the public. URI is an acceptable means of calculating off-site dose due to a radioactive releasebecause it estimates the plume's isotopic content and performs the requisite dose calculations for TEDE and CDEthyroid. Implementation of URI will not affect the classification and emergency action level scheme as described in NEI99-01, Revision 5 and continues to comply with this planning standard. Attachment 1 provides a more detaileddiscussion 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 assessingand 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 performedrepresentative practical exercises on URI and METPAC/ODPS. The data produced by URI, although not Identical tothose of METPAC/ODPS because the URI model is state-of-the-art, showed results and projected plume trajectory thatare comparable to that produced by METPACIODPS. URI Incorporates site-specific terrain, release pathways, processreduction factors, filter efficiencles, monitor response information, meteorological tower features, and other dataassociated 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 uponimplementation of this change.10 CFR 50.47(bX10) -Protective Actions: A range of protective actions has been developed for the plume exposurepathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given toevacuation, 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) EVALUATIONSHErr 5 oF 8Procedure/Document Number: Emergency Plan I Revision: 55EquipmentiFacility/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanI IEvacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuationtime estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent withFederal guidance, are developed and In place, and protective actions for the Ingestion exposure pathway EPZappropriate to the locale have been developed.Shie Comnllnce: In developing this range of actions, consideration has been given to evacuation, sheltering, and, as asupplement to these, the prophylactic use of potassium iodide (KI) when appropriate. Evacuation time estimates havebeen developed and are updated on a periodic basis. Guidelines for the choice of protective actions during anemergency appropriate to the locale and consistent with Federal guidance are In place. Implementation of URI does notaffect the mechanism for recommending protective actions to state or local authorities because it does not alter theProtective Action Recommendation process currently used at Vermont Yankee. Therefore, Implementation of URI Is incompliance with this planning standard. Attachment 1 provides a more detailed discussion of why this regulatorystandard will continue to be met upon Implementation of this change.Part IV. Description of Emergency Plan Planning Standards, Functions and Program ElementsAffected by the Proposed Change:Medical Response Team10 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., 24/7support).Sections IV.A.1-iV.A.9 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear InSection 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 criteriaappear 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.Lof 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) isestablished." Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, anddemonstrate 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.Nof NUREG-0654 and the licensee's emergency plan..10 CFR 50.47(b)(1 51 -Emeraencv Responder Training0 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 11.0of NUREG-0654 and the licensee's emergency plan.EN-EP-305 REV 3 ATrACHMENT 9.2 1 OCFR50.54(q) EVALUATIONSHEET 6 OF 8Procedure/Document Number: Emergency Plan Revision: 56EquipmentiFacility/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanUnified Rascal Interface10 CFR 50.47(bl(41 -Emeraencv Classification Systema 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 InSection 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 InSection 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 tosupport 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 forhostile 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 PlanFunctions:Medical Reseonse TeamCurrently, the VY Emergency Plan refers to the Medical Response Team and Indicates it provides onsite medicaltreatment. However, the Medical Response Team is not onsite on a 24-hour per day basis and VY's current on-shiftstaffing 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 aidresponsibilities are assigned to the Firs Brigade. The proposed changes to Section 10.5.1 and 12.1.4, revise thesesections consistent with Table 8.4 and the responsibilities assigned In the VY staffing analyses.Unified Rascal InterfaceCurrently, Section 10.1.1 (Initial Offsite Radiological Dose Projection Capability) of the vY Emergency Plan addressesthe initial evaluation of offsite radiological conditions using the ODPS. The revisions to the Emergency Plan will eliminatereference to the ODPS. Section 10.1.2, refers to the 'model described in Section 10.1.1" when describing the modeldose projection capabilities. Section 10.1.2 will eliminate references to Section 10.1.1 while continuing to provide anappropriate description of dose assessment capabilities.Regulatory Guide 1.219, "Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors providesguidance 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 planrequires prior NRC approval. Rrst the test assesses whether the emergency plan, as modified, would continue tocomply 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 testsare separate and distinct. if the licensee does not meet either test, it must obtain prior NRC approval. Meeting the firstEN-EP-305 REV 3 ArrACHMENT 9.2 1 OCFRSO.$4(q) EVALUATIONSHEET 7 OF 8Procedure/Document Number: Emergency Plan { Revlslon: 55EquipmentlFaclllty/Other: Vermont YankeeTitle: Vermont Yankee Emergency Planteat does not Imply that the licensee has met the second test, nor does meeting the second test Imply that the licenseehas met the first test.REGULATORY GUIDE 1.219 TEST PART 1: (Does the chanoe comply with reoulatlons?)Medical Response TeamThe licensee organizational description, staffing levels and assignment of responsibilities required by 10 CFR50.47(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 EmergencyResponse Organization (ERO) Is described in Section 8.2 of the VY Emergency Plan. In Table 8.4, first aidresponsibilities are assigned to the Fire Brigade. The current VY On-Shift Staffing Analysis Report. Rev. 1 (December19, 2013) and the VY analysis presented In BVY 14-018, developed In accordance with NEI 10-05, do not consider theMedical 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 firebrigade stall Is trained in first aid and rescue operations and Is available to perform these tasks If required, on a 24-hourper 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 Isdelineated 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, Isdelineated In Sections 10.5 and 12.1.4. Section 10.6.1 states that Medical Response Team members are trained Inaccordance with station procedures. Section 10.5.2 addresses arrangements to transport contaminated injuredIndividuals offsite for treatment. Section 12.1.4 states that to evaluate the training of the medical response team andofisite medical response (ambulance and hospital), a medical drill Is conducted annually with a simulated contaminatedInjured Individual. The station fire brigade staff is trained in first aid and rescue operations and Is available to performthese tasks if required, on a 24-hour per day basis.Unified Rascal InterfaceThe method used to perform dose assessment Is discussed in Section 10 of the Emergency Plan and the EmergencyPlan 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 calculationengine from RASCAL, discussion of the differences between the two dose assessment models, assessment of theimpact 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 TeamThe emergency plan and its Implementing procedures will continue to assign responsibilities for medical response. Withrespect to medical support personnel, VY's use of the Medical Response Team exceeds the guidance contained InNUREG-0654-FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness In Support of Nuclear Power Plants (NUREG-0654)." This level of response represents a sell-imposedcommitment that exceeds regulatory standards and requirements. Because the medical response continues to complywith applicable regulations and training provided for medical response personnel will continue to meet or exceed the RedCross Multi-Media training Identified In NUREG-0654 Planning Standard 0, Evaluation Criteria 3, the proposed changesto eliminate the Medical Response Team and the subsequent changes to Sections 10.5.1 and 12.1.4 of the VYEmergency 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 theanalysis for the proposed post-shutdown on-shift staffing proposed In BVY 14-018 do not consider the presence of theMedical Response Team, and VY Emergency Plan Table 5.4 assigns first aid responsibilities to the Fire Brigade, theproposed change to eliminate the Medical Response Team continues to comply with the applicable requirementscontained In 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. This change continues to align with the requirementsof Appendix E to 10 CFR Part 50 and does not represent a reduction in the effectiveness of the Emergency Plan andcan be implemented without prior NRC approval.EN-EP-305 REV 3 ATTACHMENT 9.2SHEET 8 OF 81 OCFR5O.54(q) EVALUATIONProcedure/Document Number: Emergency Plan I RevliIon: 55Equipment/Facility/Other: Vermont YankeeTitle: Vermont Yankee Emergency PlanUnified Rascal InterfaceThe impact of the proposed changes will be to improve the ability of Vermont Yankee to protect the health and safety ofthe public by providing an improved process to calculate estimates of offsite airborne concentrations and dose ratesIncluding those resulting from multiple release points. Attachment I contains a detailed effectiveness review of thischange including a description of the underlying calculation engine from RASCAL, discussion of the differences betweenthe two dose assessment models, assessment of the impact of the changes to the planning standards, and othersupporting information.Adopting URI as the primary dose assessment software continues to comply with the planning standards outlined in 10CFR 50.47 (b) 4,9. and 10. Replacing METPAC/ODPS with URI is not a reduction In the effectiveness of theEmergency Plan and can be incorporated without prior NRC approval.Part VI. Evaluation ConclusionAnswer 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 NO2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no OYES 3 NOreduction in effectiveness)? aYES -NO3. Does the proposed change constitute an emergency action level scheme change?_ [OYES [] NOIf questions I or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify theproposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR50.90. If questions I and 2 are answered YES, and quesion 3 answered NO, Implement applicable changeprocess(es). Refer to step 5.6[8].Part VII. SignaturesPreparer 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 1-2-2015Nuclear EP Project Manager -26-2015Approver Name (Print) Approver Signature Date:MP McKenneyEP Manager or designeeZ1 , 5EN-EP-305 REV 3

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1of the URIURASCAL Underlying ImplementationThe Unified RASCAL Interface (URI) computer program Is a new dose assessment program based on thecalculation engine of the NRC code RASCAL. This dose assessment program will replace the site-specificdose assessment codes currently in use at Vermont Yankee. This 50.54(q) evaluation will evaluate thefollowing 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 ProgramThe reason for the change Is to implement the new atmospheric dispersion models of RASCAL that offer astreamlined user Interface utilizing instrumentation and terminology available at the site. The new dispersionmodels used in the NRC's RASCAL code have been extensively verified and validated as referenced InSection 4.10 of the RASCAL 4, "Description of Models and Methods", June 2, 2010. The RASCAL dispersionmodels provide a more accurate depiction of plume dispersion as compared to the Department of EnergyMESODIF-Il methodology currently employed by the Meteorological Plant Access Computer (METPAC). Thenew dispersion models will ensure a more accurate estimate of the dose to the public when compared toMETPAC/ODPS.URI consists of the following dose assessment methodologies.Rapid Assessment: Can be used by the on-shift dose assessor to perform dose assessments withminimal information available. Rapid Assessment includes assessment methodologies using effluentmonitors, containment high range area monitors and pre-determined fuel damage estimates. Thedecision for on-shift personnel to use the rapid assessment instead of the detail assessment has notbeen made at this time.Detailed Assessment: is used by the augmented emergency response staff in the TSC or EOF where amuch greater degree of source term and plant status Information will be available to perform more refinedassessments. Detailed Assessment includes assessment methodologies using effluent monitors,containment high range area monitors, fuel damage estimates, effluent sample results, and field teamresults.URI consists of a front and back end interface to the NRC's RASCAL computer code. In its simplest form theURI code operates as follows.1. Based on user Input the program calculates a release rate for a given set of isotopes and produces afile formatted to meet the RASCAL input requirements.2. Based on user input the program creates a meteorological data file formatted to meet the RASCALinput 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 Dose5. The URI program reads the RASCAL output files containing the calculated data and displays the datain standard reports and forms.Page 1 of 10

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IDetails 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, anadditional computer program referred to as the maintenance program exists. This program Is used tomaintain pertinent information within a database related to the site and to generate the encrypted file whenchanges to the underlying data are made. This program only creates a data file used by the URI programs; itdoes not actually perform dose assessment functions.Proaram Reauirements50.47(bX4) A standard emergency classification and action level scheme, the bases of which include facilitysystem and effluent parameters, Is in use by the nuclear facility licensee, and State and local response planscall for reliance on information provided by facility licensees for determinations 01 mInimum initial offseteresponse measures.NUREG-0654 II.D1. An emergency classification and emergency action level scheme as set forth In Appendix I must beestablished by the licensee. The specific instruments, parameters, or equipment status shall beshown for establishing each emergency class In the in-plant emergency procedures. The plan shallIdentify 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 potentialoffsite consequences of a radiological emergency condition are in use.NUREG-0654 11.11. Each licensee shall identify plant system and effluent parameter values characteristic of a spectrumof off-normal conditions and accidents, and shall Identify the plant parameter values or otherinformation which correspond to the example Initiating conditions of Appendix 1. Such parametervalues and the corresponding emergency class shall be included in the appropriate facilityemergency procedures. Facility emergency procedures shall specify the kinds of Instruments beingused and their capabilities.2. Onsite capability and resources to provide Initial values and continuing assessment throughout thecourse 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 therelationship between the containment radiation monitor(s) reading(s) and radioactive materialavailable for release from containment.b. the magnitude of the release of radioactive materials based on plant system parameters andeffluent monitors.4. Each licensee shall establish the relationship between effluent monitor readings and onsite andoffsite exposures and contamination for various meteorological conditions.5. Each licensee shall have the capability of acquiring and evaluating meteorological informationsufficient to meet the criteria of Appendix 2. There shall be provisions for access to meteorologicalinformation 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 suitablemeteorological 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

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I6. Each licensee shall establish the methodology for determining the release rate/projected doses if theinstrumentation used for assessment Is offscale or Inoperable.7. Each organization shall describe the capability and resources for field monitoring within the plumeexposure Emergency Planning Zone which are an intrinsic part of the concept of operations for thefacility.8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapidassessments of the actual or potential magnitude and locations of any radiological hazards throughliquid or gaseous release pathways. This shall include activation, notification means, field teamcomposition, transportation, communication, monitoring equipment and estimated deployment times.9. Each organization shall have a capability to detect and measure radiolodine concentrations In air inthe plume exposure EPZ as low as 107 pci/cc (microcuries per cubic centimeter) under fieldconditions. Interference from the presence of noble gas and background radiation shall not decreasethe 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 InTable 3, page 18) and gross radioactivity measurements. Provisions shall be made for estimatingIntegrated dose from the projected and actual dose rates and for comparing these estimates with theprotective 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 foremergency workers and the public. In developing this range of actions, consideration has been given toevacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), asappropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shallupdate the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actionsduring an emergency, consistent with Federal guidance, are developed and in place, and protective actionsfor the Ingestion exposure pathway EPZ appropriate to the locale have been developed.NUREG-0854 II.J7. Each licensee shall establish a mechanism for recommending protective actions to the appropriateState and local authorities. These shall Include Emergency Action Levels corresponding to projecteddose to the population-at-risk, in accordance with Appendix 1 and with the recommendations set forthin Tables 2.1 and 2.2 of the Manual of Protective Action Guides and Protective Actions for NuclearIncidents (EPA-52011-75-001). As specified in Appendix 1, prompt notification shall be made directlyto the offsite authorities responsible for Implementing protective measures within the plume exposurepathway Emergency Planning Zone.Change ComparlsonURI represents an improvement over METPAC/ODPS. The URI dose assessment program retains all of thesite specific parameters and inputs that were common to the METPAC/ODPS program. Therefore, there areno changes to site specific parameters and inputs that Impact compliance with the program requirementsabove. A site specific analysis was performed to validate and verify all release pathways. Monitors andrelease 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 codeImplements a Lagranglan trajectory, Gaussian puff dispersion model. Transport, diffusion, and deposition ofmaterial In the puffs are controlled by wind, atmospheric stability, precipitation, and mixing-layer depth fieldsthat describe the spatial and temporal variations of meteorological conditions throughout the domain.Page 3 of 10

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1The methodology for calculating diffusion coefficients in RATCHET uses the turbulence parameters sigma vand sigma w. Sigma v is the standard deviation of the fluctuation of the horizontal component of the windvector perpendicular to the mean wind direction. Sigma w Is the standard deviation of the vertical componentof the wind vector. RATCHET therefore calculates the dispersion parameters as needed based on currentatmospheric and surface conditions. Because of this, the dispersion parameters are a function of time andnot distance like the classic Pasquili-Gifford curves.URI uses the RASCAL TADPLUME40.dil and TADPUFF40.dIl computer files to calculate dose. As such, thedose conversion factors have changed when compared to those used In METPACIODPS. The doseconversion factors used in RASCAL are based primarily on Federal Guidance Report Number 11 and FederalGuidance Report Number 12, "External Exposure to Radionuclides in Air, Water, and Soil". FederalGuidance Report Number 12 is a newer reference than DOE 1988 and therefore has updated doseconversion factors.RASCAL is a sophisticated model that performs calculations for cloud shine dose doing actual integrationsover the model domain.The RATCHET Code has been validated in a number of tests. The algorithms used have been extensivelyreviewed by leading experts in the field Including the National Academy of Sciences. As documented insection 4.10 of the RASCAL Manual, the reasons the RATCHET algorithms were used in RASCAL is that theRATCHET code has received extensive peer review and validation. The RATCHET code has also beenvalidated 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 RASCAL4.0 and 4.1 to be consistent with Turbo FRMAC 2010.Another study of different dose models was performed in NUREG/CR-6853, "COMPARISON OF AVERAGETRANSORT 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 olderversion of RASCAL, and a simplified Gaussian model, MACCS2. In this particular test, each model was runto produce the annual average integrated exposure and deposition for a series of rings from 10 to 100 milesfrom a hypothetical release. The conclusion from these studies, as referenced in the current RASCALManual, 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 1mph) weather conditions. URI uses RASCAL's meteorological processor and dose processors. Thisincorporates the use of multiple meteorological off-site towers and topographical data. In 1977, the AmericanMeteorological Society Committee on Atmospheric Turbulence and Diffusion estimated the upper limit ofaccuracy for diffusion models to be about a factor of two under conditions where the meteorologicalparameters controlling diffusion are measured near the point of release and where topographic relief isminimal., A greater uncertainty approaching a factor of 10 was established for conditions when the windspeed decreases toward calm. As previously stated, implementing calm weather conditions was one of thebenefits 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 inRASCAL and therefore have been evaluated and benchmarked against other methodologies. Testing hasbeen performed to ensure that the specific URI version produces reasonable results when compared toRASCAL.There are three main reasons for changing Vermont Yankee's dose assessment program fromMETPAC/ODPS to URI. First, METPAC/ODPS Is a DOS based program which cannot be run in the currentWindows 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 mixtureexpected from the release of primary coolant at equilibrium concentrations with one percent failed fuel and aLOCA III category which uses the mixture expected from some degree of core damage that has resulted In arapid release of fission products into reactor coolant. These are not applicable to a permanently defueledplant where the spent fuel pool and Independent Spent Fuel Storage casks are the sources of a release tothe environment. Finally, URI is capable of automated multi-source dose assessment while METPAC/ODPSIs not.Page 4 of 10

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1Chanae Assessment50.47(b)(4) A standard emergency classification and action level scheme, the bases of which Include facilitysystem and effluent parameters, Is in use by the nuclear facility licensee, and State and local response planscall for reliance on information provided by facility licensees for determinations of minimum Initial offsiteresponse measures.NUREG-0654 II.D1. An emergency classification and emergency action level scheme as set forth In Appendix 1must be established by the licensee. The specific Instruments, parameters or equipmentstatus shall be shown for establishing each emergency class, In the In-plant emergencyprocedures. The plan shall identify the parameter values and equipment status for eachemergency class.Implementation of URI will not affect the classification and emergency action level scheme as describedIn NEI-99-01. URI, like METPACIODPS, is a dose assessment model used as a tool to determine if anemergency classification has been exceeded. Vermont Yankee has two EALs that are tied to doseassessment. 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 donot delineate the method for determining the calculated dose to the public. URI Is an acceptable meansof calculating off-site dose due to a radioactive release because it estimates the plume's isotopic contentand 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 thisplanning standard.50.47(bX9) Adequate methods, systems, and equipment for assessing and monitoring actual or potentialoffsite consequences of a radiological emergency condition are in use.NUREG-0654 11.11. Each licensee shall identify plant system and effluent parameter values characteristic of aspectrum of off-normal conditions and accidents, and shall Identify the plant parameter valuesor other Information which correspond to the example Initiating conditions of Appendix 1.Such parameter values and the corresponding emergency class shall be Included In theappropriate facility emergency procedures. Facility emergency procedures shall specify thekinds of Instruments being used and their capabilities.URI is structured so that all pertinent effluent monitors and radiation monitors that may provide an earlyindication of off normal conditions are available as inputs to perform dose assessment. URI providesmethods to limit the entered value for each monitor used in an assessment along with other limitingfunctions such as not allowing assessments to be performed using non-pertinent data points orinformation. Implementation of URI/RASCAL supports spent fuel as well as ISFSI accidents andcontinues to comply with this planning standard.2. Onslte capability and resources to provide Initial values and continuing assessmentthroughout the course of an accident shall Include post-accident sampling capability,mdlatlon and effluent monitors, In-plant Iodine Instrumentation, and containment radiationmonitodng In accordance with NUREG-0578, as elaborated in the NRC letter to all powerreactor licensees dated October 30, 1979.URI is structured so that all spent fuel and ISFSI accident instrumentation Is available for input into thedose assessment model. Implementation of URIJRASCAL continues to comply with this planningstandard.Page 5 of 10

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I3. 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 exampleis the relationship between the containment radiation monitor(s) reading(s) andradioactive material available for release from containment.Spent Fuel AccidentIn the case of a spent fuel accident, source terms are available for the fuel being underwater, partiallyuncovered, or dry. If the fuel Is underwater, the fuel Is assumed to be cooled and the only damage towould be to the cladding. Percentage of damage Is limited to the design basis accident event describedin 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% ofthe fuel from a standard core Is Involved in this type of accident. The source term Is adjusted accordinglybased on the 100% MWth power using the uCiIMWth values described in the Reactor Core Accidentsection of the Vermont Yankee URI Site Annex.Available release activities for each isotope are adjusted by spent fuel release fractions associated withthe status of the fuel (under water or exposed to air). Release fractions for spent fuel were obtained fromTable 2.1 of the RASCAL 4: Description of Models and Methods document and Table 3.2 of NUREG/CR-6451.Release Point Sample-Analysis ResultsAn additional source term is available based on a user entered release rate or concentration for each ofthe 33 isotopes of Interest. These values are obtained based on actual samples at the release point tothe environment. Since the actual values cannot be pre-determined, the user Is required to enter thesevalues manually. Doing so over-rides any assumed mixtures based on pre-determined values. Anyvalues not entered are assumed to be 0.Field Team Survey ResultsValues for collection and counting efficiency of the Instruments used at Vermont Yankee are incorporatedInto the calculation. A conversion factor derived by dividing the EPA-400 CDE thyroid factor of 1.3 E+06by the EPA-400 breathing rate of 1.2 E+06 is then applied to the field monitoring team data to perform thedose assessment.Implementation of URVRASCAL uses a source term that supports spent fuel as well as ISFSI accidentswhich 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 systemparameters and effluent monitors.URI has the capability to utilize data from installed effluent monitors or portable Instrumentation todetermine the magnitude of a release. Monitor readings are converted to release rates for each Isotopebased on a predetermined monitor conversion factor. Conversion factors are based on the Isotopes usedfor each monitor's calibration. Monitor responses can be further adjusted based on isotopic correctionfactors or time dependent correction factors due to expected changes In effluent isotopic mixture ratiosresulting from radioactive decay.Page 6 of 10

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IURI also applies factors which reduce the particulate and Iodine release rates due to mechanicalprocesses such as hold-up times and ventilation filtration. These functions are related to the pathwaythat the effluent takes from Its source to the environment. These mechanical processes can have asignificant effect on the total activity released to the environment. All the reduction factors are assumedto operate on all radionuclides except noble gases. None of the reduction factors reduce the activity ofthe noble gas release to the environment. All nuclides subject to a given reduction mechanism areassumed to have the same reduction factor. Radioiodines are treated the same as all other non-noblegas nuclides. These are the same assumptions described in Section 1.4 of the RASCAL 4: Description ofModels and Methods document.URI uses the NUREG-1228 pathways as a starting point. URI expands on these to make it easier toidentify the pathway of interest without having to Interpret mechanical processes that might or might notbe applicable to the actual pathway the effluent is taking to the environment. The number of decisionsneeded to apply mechanical process has been streamlined to only those applicable to the actualconditions.Implementation of URI/RASCAL allows for adjustment of the magnitude of a release based on systemparameters which is considered an enhancement to the dose assessment process. Its use continues tocomply with this planning standard.4. Each licensee shall establish the relationship between effluent monitor readings and onsiteand offsite exposures and contamination for various meteorological conditions.URI provides methodologies for calculating release rates using release point effluent monitors. TheMonitored Release methodology uses conversion factors for each release point to determine anequivalent gross concentration or release rate depending on how the data Is delivered from the PlantData System. URI can do additional calculations using Individual isotopic conversion factors or timedependent conversion factors. These are described in detail in the Requirements Specification andVermont Yankee URI Site Annex. When a calculation is performed, a release rate Is calculated andprocessed using the RASCAL dose processors.URI uses predetermined onsite meteorological tower data and optional meteorological data from offsitesources. Required Input fields are wind speed, wind direction, stability class, and precipitation. When acalculation Is performed, all entered meteorological data is processed in RASCAL using themeteorological processor.Implementation of URI/RASCAL establishes a relationship between effluent monitor readings and offsiteexposures and contamination for entered metrological conditions which continues to comply with thisplanning standard.5. Each licensee shall have the capability of acquiring and evaluating meteorological Informationsufficient to meet the criteria of Appendix 2. There shall be provisions for access tometeorological Information by at least the near-site Emergency Operations Facility, theTechnical Support Center, the Control Room and an offolte NRC center. The licensee shallmake available to the State suitable meteorological data processing Interconnections whichwill permit independent analysis by the State, of facility generated data in those States withthe resources to effectively use this Information.URI does not require additional meteorological data beyond what is required for METPAC/ODPS. URIdoes have additional capabilities beyond that of METPAC/ODPS in that it can utilize multiplemeteorological towers for dose assessment. Implementing URI will have no effect on availablemeteorological towers and their associated information at a Vermont Yankee emergency facility or at astate or federal facility. Provision for data processing interconnections associated with the sitemeteorological monitoring program remains unchanged.Implementation of URI/RASCAL continues to comply with this planning standard.Page 7 of 10

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16. Each licenase shall establish the methodology for determining the release rate/projecteddoses if the Instrumentation used for assessment Is offecale or Inoperable.Normally, assessments are performed using installed or portable effluent monitors. However, when theyare not available or not part of the release pathway, URI provides alternative methods to calculate arelease rate. Subsequent projected doses are based on the calculated release rate using the RASCALmeteorological and dose processors. A unique dose calculation model Is not required for each alternatemethod to determine a calculated dose.Release Point SampleResult concentrations for the 33 isotopes of interest can be entered directly into the program to determinea release rate based on a given release point flow rate. Any isotope concentrations not entered areassumed to be 0.Field TeamResults can be utilized to back calculate a source term and subsequent doses by rationing apredetermined release to actual field team results. Field team environmental data with input fields forexposure rate and iodine concentration are used to calculate a release rate ratio. URI results are thenadjusted 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 theplume exposure Emergency Planning Zone which are an Intrinsic part of the concept ofoperations for the facility.Implementation of URI/RASCAL does not affect field monitoring activities and continues to comply withthis planning standard. However, field monitoring team results can be used to calculate projected dosesas described in 6 above.8. Each organization, where appropriate, shall provide methods, equipment and expertise tomake rapid assessments of the actual or potential magnitude and locations of any radiologicalhazards through liquid or gaseous release pathways. This shall Include activation,notification means, field team composition, transportation, communication, monitoringequipment 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 withthis planning standard.9. Each organization shall have a capability to detect and measure radiolodine concentrations inair In the plume exposure EPZ as low as 10.' ucilcc (microcurles per cubic centimeter) underfield conditions. Interference from the presence of noble gas and background radiation shallnot 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. Minimumdetectable activities are determined based on sample collection efficiency, sample volume, and countingequipment efficiency. URI does provide a method for calculating particulate and Iodine air sample resultsincluding a Lower Limit of Detection (LLD) value to help determine the validity of the sample results whenused for dose assessment.Implementation of URI/RASCAL continues to comply with this planning standard.Page 8 of 10

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I10. 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., thosegiven In Table 3, page 18) and gross radioactivity measurements. Provisions shall be madefor estimating Integrated dose from the projected and actual dose rates and for comparingthese estimates with the protective action guides. The detailed provisions shall be describedIn separate procedures.URI provides methodologies to convert airborne activity levels to dose based on calculated gaseousrelease rates for a given set of isotopes. These isotopes are defined in NUREG 1228 Table 2.2. These33 isotopes are based on the WASH-1400 values that contribute to early health effects. All of theisotopes 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 thecurrent evacuation time estimate for release duration. In either case, the integrated dose Is compared tothe EPA PAG values. Areas where the PAGs are exceeded are highlighted on a graphical display. Thismethod 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 foremergency workers and the public. In developing this range of actions, consideration has been given toevacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), asappropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shallupdate the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actionsduring an emergency, consistent with Federal guidance, are developed and in place, and protective actionsfor the ingestion exposure pathway EPZ appropriate to the locale have been developed.NUREG-0654 II.J7. Each licensee shall establish a mechanism for recommending protective actions to theappropriate State and local authorities. These shall Include Emergency Action Levelscorresponding to projected dose to the population-at-risk, in accordance with Appendix I andwith the recommendations set forth in Tables 2.1 and 2.2 of the Manual of Protective ActionGuides and Protective Actions for Nuclear Incidents (EPA-520/1-75-001). As specified InAppendix 1, prompt notification shall be made directly to the offslte authorities responsiblefor implementing protective measures within the plume exposure pathway EmergencyPlanning Zone.In developing this range of actions, consideration has been given to evacuation, sheltering, and, as asupplement to these, the prophylactic use of potassium iodide (KI) when appropriate. Evacuation timeestimates have been developed and are updated on a periodic basis. Guidelines for the choice ofprotective actions during an emergency appropriate to the locale and consistent with Federal guidanceare In place. Implementation of URI does not affect the mechanism for recommending protective actionsto state or local authorities because it does not alter the Protective Action Recommendation processcurrently used at Vermont Yankee.Implementation of URI/RASCAL continues to comply with this planning standard.Page 9 of 10

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1ReferencesRASCAL 4, "Description of Models and Methods", June 2, 2010Regulatory Guide 1.145, "ATMOSPERIC DISPERSION MODELS FOR POTENTIAL ACCIDENTCONSEQUENCE ASSESSMENTS AT NUCLEAR POWER PLANTS",PAVAN (Bander, T.J. 1982), NUREG/CR-2858 "An Atmospheric Dispersion Program for Evaluating DesignBasis Accidental Releases for Radioactive Materials from Nuclear Power Stations"XOQDOQ (Sagendorf, Gol, and Sanddursky 1982.) NUREG/CR 4380, "Computer Program for theMeteorological 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 DOSEANALYSIS"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 andDose Conversion Factors for Inhalation, Submersion and Ingestion".Federal Guidance Report Number 12, "External Exposure to Radlonuclides in Air, Water, andSoir.NUREG/CR-6853, "COMPARISON OF AVERAGE TRANSORT AND DISPERSION AMONG A GAUSSIAN,A TWO-DIMENSIONAL AND A THREE-DIMENSIONAL MODEL", October 2004.NEI -99-01, "Methodology for Development of Emergency Action Levels"Page 10 of 10 ATTACHMENT 9.1SHEET 1 OF 31OCFR50.54(q) SCREENINGProcedure/Document Number: Emergency Plan Revision: 55EquipmentlFacility/Other: Vermont Yankee ERDSTitle: Vermont Yankee Emergency PlanPart I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a changeto the emergency plan or affect the Implementation of the emergency plan):This screening addresses the retirement of the Emergency Response Data System (ERDS) in theEmergency 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 PlanningData Management," and AP-1 0049, "Equipment Important to Emergency Response' and the removal ofVermont Yankee from EN-EP-31 1," Emergency Response Data System (ERDS) Activation via the VirtualPrivate Network (VPN)."Part II. Activity Previously Reviewed? E]YESIs this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue toAlert and Notification System Design Report? Evaluation is next partNOT required.EnterIf YES, identify bounding source document number/approval reference and justificationensure the basis for concluding the source document fully bounds the below andproposed change is documented below: complete PartVI.Justification:[I Bounding document attached (optional)Part III. Applicability of Other Regulatory Change Control ProcessesCheck 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 toother documents which have a different change control process and are NOT to be included in this 50.54(q)(3)Screening.APPLICABILITY CONCLUSION0 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 theemergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portionof 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 PROCESSES10 CFR 50.54(q)Part IV. Editorial Change D-OYES 10 NO50.54(q)(3) Continue to nextIs this activity an editorial or typographical change such as formatting, paragraph Evaluation is partnumbering, spelling, or punctuation that does not change intent? NOT required.Justification- Enterjustification andcomplete PartVI.EN-EP-305 REV 3 ATTACHMENT 9.1SHEET 2 OF 310CFR5O.54(q) SCREENINGProcedure/Document Number: Emergency Plan Revision: 55EquipmentlFacility/Other: Vermont Yankee ERDSTitle: Vermont Yankee Emergency PlanPart V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard functionidentifled 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 5staffing) in accordance with the emergency plan. (1]3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] M4. 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 El6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [31 El7. A standard scheme of emergency classification and action levels is in use. [4] 58. Procedures for notification of State and local governmental agencies are capable of alerting them of Elthe 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 5instructions 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 andNotification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANSdesign report and supporting FEMA approval letter. [5]11. Systems are established for prompt communication among principal emergency responseorganizations. [6112. Systems are established for prompt communication to emergency response personnel. [6] El13. Emergency preparedness information is made available to the public on a periodic basis within theplume 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] El16. Adequate equipment is maintained to support emergency response. [8] E]17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] El18. 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 Liavailable to support the formulation of PARs and have been provided to State and localgovernmental authorities. [10]20. A range of protective actions is available for plant emergency workers during emergencies, includingthose for hostile action events.[1 0]EN-EP-305 REV 3 ATTACHMENT 9.1SHEET 3 OF 310CFR50.54(q) SCREENINGProcedure/Document Number: Emergency Plan Revision: 55Equipment/FacilitylOther: Vermont Yankee ERDSTitle: Vermont Yankee Emergency Plan21. The resources for controlling radiological exposures for emergency workers are established. [11]22. Arrangements are made for medical services for contaminated, injured individuals. (12123. Plans for recovery and reentry are developed. (13]24. A drill and exercise program (including radiological, medical, health physics and other program 0areas) is established. [14)25. Drills, exercises, and training evolutions that provide performance opportunities to develop, Elmaintain, and demonstrate key skills are assessed via a formal critique process in order to identifyweaknesses. (14126. Identified weaknesses are corrected. [14]27. Training is provided to emergency responders. (15] 028. Responsibility for emergency plan development and review is established. [16] El29. Planners responsible for emergency plan development and maintenance are properly trained. [16) ___...APPLICABILITY CONCLUSIONO If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion belowand complete Part VI.If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.BASIS FOR CONCLUSIONEmergency Planning Standard 10 CFR 50.47(b)(6) and planning standard element 11 in Part V of this formare affected by the retirement of ERDS. A 10 CFR 50.54(q) Evaluation will be performed to determinewhether 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./Af IEN-EP-305 REV 3 ATTACHMENT 9.2 10CFR5O.54(q) EVALUATiONSHEET 1 OF 7Procedure/Document Number: NA Revision: NAEquipmentiFacilityiOther: Vermont Yankee ERDSTitle: NAPart I. Description of Proposed Change:This evaluation addresses the retirement of the Emergency Response Data System (ERDS) and removal of ERDS fromthe 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," andAP-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 TechnicalRequirements Manual (TRM) (Rev. 53) were searched for the following keywords: Emergency Response Data Systemand ERDS. Additionally, EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "EmergencyOperations 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 DataSystem 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 forreferences to ERDS and no results were found.ERDS was Identified In the following:Emeraency PlanAccording to Section 7.10 of the VY Emergency Plan, "ERDS is a direct real-time electronic transmission of the followingtypes 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 acontinuous ERDS connection with the NRC Operations Center."UFSARSection 7.15.1 of the UFSAR (Rev. 26) states that the Process Computer System (PCS) exports data to an EmergencyResponse Data System (ERDS) function and that, once activated, ERDS sends selected current plant data points to theNRC Operations Center on a periodic basis. Section 7.15.2, Item #4 states that the PCS data export feature shall supportthe following ERDS functions (resident on another system): Capable of being manually activated within one hour; Onceactivated, will establish data communications with the NRC ERDS computer system,; Transmit critical plant data in theproper format and protocol at time intervals of not less than 15 seconds or more than 60 seconds, until the link ismanually disconnected, and; If the data connection is lost, the ERDS interface module Is responsible for re-establishingcommunication with the ERDS computer.EPOP-TSC-3542Step 1.2 of Attachment 2 of EPOP-TSC-3542 states that the TSC Manager Is responsible for ensuring the IT Specialisthas verified the ERDS connection. Step 1.2 of Attachment 12 instructs the IT Specialist to verify the ERDS connection perEN-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 initialdeclaration 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 Specialistis unable to verify the connection within the required time, then one of the following (in this order) will perform theverification: 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 VermontYankee maintains a continuous connection to the NRC.EN-EP-305 REV 3 ATTACHMENT 9.2 1OCFR50.54(q) EVALUATIONSHEET 2 OF 7Procedure/Document Number: NA ý7Revision: NAEquipment/Facillty/Other: Vermont Yankee ERDSTitle: NAEPOP-EOF-3546Step 1.2 of Attachment 6 of EPOP-EOF-3546 instructs the Offsite Communicator to confirm that the IT Specialist hasverified the ERDS connection with the NRC and to follow the Instructions in EN-EP-311 to perform the verification if the ITSpecialist has not already performed the verification. Step 3.1 of Attachment 6 of EPOP-EOF-3546 instructs the OffsiteCommunicator 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 initialdeclaration 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 Specialistis unable to verify the connection within the required time, then one of the following (in this order) will perform theverification: 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 byInterpreting information/data, if necessary, for use with NRC ERDS, METPAC, Rascal and any other computer systemsused for radiological assessment. The New Hampshire and Massachusetts Offsite Liaisons mobilize to the StateEmergency Operations Centers (EOCs). The Vermont Offsite Liaison is stationed at the EOF.EN-EP-311EN-EP-311 provides for a secure network communications connection supporting the transmission of station parametersto the NRC in the event of a declared emergency. The procedure provides the methodology for establishing the VirtualPrivate Network (VPN) communications link to the NRC for the transmission of ERDS data. The procedure also providesinstructions for verification of connections for those Entergy plants which maintain 24/7 connectivity.EPAD-0093Attachment 4 of EPAD-0093 contains Instructions for ensuring that the NRC is notified prior to a drill or exercise in whichERDS will be used and Attachment 10 contains actions taken following a drill or exercise with respect to restoration ofERDS.AP-10049AP-1 0049 identifies ERDS as equipment Important to emergency response. ERDS is described as "a direct real timeelectronic 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 PreparednessRegulation(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 NRCcommitments (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 principalresponse organizations to emergency personnel and to the public.Site Compliance: Section 7.0 of the Emergency Plan and EPOP-COMM-3504 describe the available communicationsequipment, the location of this equipment, and the procedures for communicating with on-site and off-site support groupsincluding 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 theability of the States to access ERDS for the provision of data. VY maintains the ability to provide more data (e.g., SFPparameters) 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) EVALUATIONSHEET 3 OF 7Procedure/Document Number: NA Revision: NAEquipment/Facility/Other: Vermont Yankee EROSTitle: NA10 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'sonsite computer system and the NRC Operations Center that provides for the automated transmission of a limited dataset of selected parameters. The ERDS supplements the existing voice transmission over the Emergency NotificationSystem (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parametersfrom the licensee's installed onsite computer system in the event of an emergency. When selected plant data are notavailable on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shagl test theERDS periodically to verify system availability and operability. The frequency of ERDS testing will be quarterly unlessotherwise 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, onsitehardware shall be provided at each unit by the licensee to interface with the NRC receiving system. Software, which willbe made available by the NRC, will assemble the data to be transmitted and transmit data from each unit via an outputport 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 plantmeteorological tower data. A separate data feed is required for each reactor unit. While it is recognized that ERDS is nota 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 parameterswill 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 coolantcharging/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) Safetyinjection: High- and low-pressure safety Injection flows, safety Injection flows (Westinghouse), and borated water storagetank level; (4) Containment: pressure, temperatures, hydrogen concentration, and sump levels; (5) Radiation monitoringsystem: Reactor coolant radioactivity, containment radiation level, condenser air removal radiation level, effluent radiationmonitors, and process radiation monitor levels; and (6) Meteorological data: wind speed, wind direction, and atmosphericstability.(ii) For boiling water reactors (BWRs), the selected parameters are: (1) Reactor coolant system: Reactor pressure, reactorvessel level, feedwater flow, and reactor power; (2) Safety injection: Reactor core isolation cooling flow, high-pressurecoolant injection/high-pressure core spray flow, core spray flow, low-pressure coolant injection flow, and condensatestorage tank level; (3) Containment: drywell pressure, drywell temperatures, drywell sump levels, hydrogen and oxygenconcentrations, suppression pool temperature, and suppression pool level; (4) Radiation monitoring system: Reactorcoolant radioactivity level, primary containment radiation level, condenser off-gas radiation level, effluent radiationmonitor, 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 15seconds 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 asconfigured 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 changesare completed.b. Hardware and software changes, with the exception of data point modifications, that could affect the transmissionformat and computer communication protocol to the ERDS must be provided to the NRC as soon as practicable and atleast 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 forlicensee installation.4. Implementing the Emergency Response Data System Program:EN-EP-305 REV 3 ATTACHMENT 9.2 10CFR5O.54(q) EVALUATIONSHEET 4 OF 7Procedure/Document Number: NA 7 Revision: NAEquipmentIFacllity/Other: Vermont Yankee ERDSTitle: NAa. Each licensee shall develop and submit an ERDS implementation program plan to the NRC by October 28, 1991. Toensure 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 berequired 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 fullpower, whichever comes later. Licensees with currently operational ERDS interfaces approved under the voluntary ERDSimplementation program will not be required to submit another implementation plan and will be considered to have metthe 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 SupportCenter," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," VY currently maintains acontinuous 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 whohave submitted a certificate of permanent cessation of operation of a nuclear power facility. Per NRC memoranda dated6/2/14 (ML1 4099A520), the objective of ERDS, since its Inception, has been to facilitate NRC monitoring of licenseeresponse 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 permanentremoval 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 50license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel Into the reactor vesseland the requirements for ERDS in 10 CFR 50 Appendix E section VI.2 will no longer apply. Because Section VI ofAppendix E to 10 CFR Part 50 is not applicable to permanently shutdown facilities, the emergency plan, as modified, willcontinue to meet the applicable requirements.10 CFR 50.72(aX4) -ERDS Activation: The licensee shall activate the Emergency Response Data System (ERDS) -assoon as possible but not later than one hour after declaring an Emergency Class of alert, site area emergency, or generalemergency. The ERDS may also be activated by the licensee during emergency drills or exercises if the licensee'scomputer 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 toERDS, an initial verification of the ERDS connection with the NRC following declaration of an emergency is currentlyperformed 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 DepartmentPersonnel. Because ERDS requirements are not applicable to facilities which have permanently ceased operations, therecan be no required ERDS for such a facility to activate and the emergency plan, as modified, will continue to meet theapplicable requirements.10 CFR 50.72(c)(3) -Continuous Communication: Maintain an open, continuous communication channel with the NRCOperations 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 OperationsCenter 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, withextensions In the Communications Room and the NRC Room of the TSC. The ENS also utilizes a separate FTS linebetween 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) EVALUATIONSHEET 5 OF 7Procedure/Document Number: NA Revision: NAEquipment[Facility/Other: Vermont Yankee EROSTitle: NAPart IV. Description of Emergency Plan Planning Standards, Functions and Program ElementsAffected 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 ofNUREG-0654 and the licensee's emergency plan.Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency PlanFunctions:Regulatory Guide 1.219, "Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors' providesguidance 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 planrequires prior NRC approval. First, the test assesses whether the emergency plan, as modified, would continue to complywith the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR Part 50. Second, the testassesses whether the proposed change would reduce the effectiveness of the emergency plan. These two tests areseparate and distinct. ff the licensee does not meet either test, it must obtain prior NRC approval. Meeting the first testdoes not imply that the licensee has met the second test, nor does meeting the second test imply that the licensee hasmet 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 toemergency personnel and to the public.The VY Emergency Plan does not rely upon ERDS for transmission of Informationor data to the State or local authorities or to the public. Section 7.0 of the emergency plan identifies the means ofcommunication with State and local authorities. This is accomplished via InForm, Nuclear Alert System, Mobile UHFRadio System, commercial telephone system, and facsimile. EROS is not identified as a communication channel to Stateresponse organizations; it is one of the communication channels between VY and the NRC. Therefore, the removal ofERDS from the Emergency Plan would not affect the ability of VY to maintain prompt communication among principalresponse 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 permanentremoval 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 50license 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 forProduction and Utilization Facilities,"Section VI, "Emergency Response Data System."Section VI(2) provides anexclusion for reactors that are permanently or indefinitely shut down. In the Statements of Consideration (SOC) for theERDS final rule (50 Federal Register 50178, August 13, 1991) the NRC stated the objective of the rule was to provide areliable and effective communication system that would allow the NRC to monitor critical parameters at operating reactorsduring an emergency. The NRC identified that it has a responsibility in the event of a reactor accident to monitor theactions of the licensee and to promptly assess the situation at the plant. The NRC described ERDS as a supplement tothe 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 powerreactor 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 theprovisions 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 tofacilities which have permanently ceased operations, the 50.72(a)(4) ERDS activiation requirement is likewiseinapplicable.EN-EP-305 REV 3 ATTAHMEN 9.21 OCR5O.4(q)EVALATIOATTACHMENT 9.2 10CFR50.54(q) EVALUATIONSHEET 6 OF 7Procedure/Document Number: NA Revision: NAEquipment/FacilitylOther: Vermont Yankee EROSTitle: NAAccordingly, the revised Emergency Plan that would reflect the retirement of ERDS would continue to comply with allapplicable 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, radiationmonitoring data, reactor building pressure data, torus water level data and meteorological data. While some of thisinformation could be used for emergency dose assessment and determination of public protective actionrecommendations, VY does not rely on ERDS for the provision of this data to the VY Emergency Response Facilities, theVY Emergency Response Organization (ERO), or to the offsite agencies. VY provides this plant data to the oftsiteauthorities via numerous other means.The PCS automatically exports data to ERDS. Separately, the Process Computer System also provides the data to theEmergency Operations Facility (EOF), Technical Support Center (TSC) and Operations Support Center (OSC) via theEmergency 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 theEmergency 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 plantcomputer system or directly from Control Room instrumentation, both of which remain available to the VY ERO In theTSC and the EOF. Similarly, the plant computer system and Control Room Instrumentation will remain available to theon-shift staff. Therefore, the retirement of ERDS would not reduce the effectiveness of VY's ability to communicate plantinformation 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, VYprovides 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 datais currently available in the EOF, TSC and OSC via the PDS. This data would be available to ERO and State personnel inthe EOF, TSC and OSC via the display screens. The VY Vermont Offsite Liaison is stationed at the EOF. The VY NewHampshire 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 usewith NRC ERDS, METPAC, Rascal and any other computer systems used for radiological assessment. The VY OffsiteLiaison positions are also maintained in the Post-Shutdown ERO and will continue to assist State personnel byinterpreting information/data from the plant computer system. Consequently, retirement of ERDS would not reduce theeffectiveness 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 alicensee's emergency plan:'...the objective of ERDS, since its Inception, has been to facilitate NRC monitoring of licenseeresponse to the event and NRC assessment of the situation at the plant. Providing ERDS data tothe NRC is not an emergency planning function as defined in 10 CFR 50.54(q)(1 )(iii). Because areduction in effectiveness requires a reduction of the licensee's capability to perform an emergencyplanning function and providing data to the NRC through ERDS is not an emergency planningfunction, removing ERDS would not reduce the effectiveness of the licensee's capability to performan emergency planning function. Accordingly, removing ERDS would not reduce the effectivenessof 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 10CFR 50.47(b)(6), 50.72(c)(3), and the remaining applicable requirements of Appendix E to 10 CFR Part 50. Removal ofERDS does not represent a reduction in effectiveness to the Emergency Plan and can be implemented without prior NRCapproval.ATTACHMENT 9.2 10CFR50.54(q) EVALUATIONSHEET 7 OF 7IP rocedure/Document Number: NA Revision: NAEN-EP-305 REV 3 Equipment/FacilitylOther: Vermont Yankee ERDSTitle: NAPart VI. Evaluation ConclusionAnswer 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 NO2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in EYES El NOeffectiveness)?3. Does the proposed change constitute an emergency action level scheme change? [:]YES 0 NOIf questions 1 or 2 are answered NO. or question 3 answered YES, reject the proposed change, modify the proposedchange and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50.90. If questions 1 and2 are answered YES, and question 3 answered NO, implement applicable change process(es). Refer to step 5.6[81.Part VII. SignaturesPreparer Name (Print) Preparer Signature Date:12/04/2014David 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 9.2IOCFR50.54(q) EvALuA-noNProcedure/Document Number: NA Revision: NAPage I of 7Equipment/Facility/Other: Vermont Yankee ERDSTitle: NAPart I. Description of Proposed Change:This evaluation has been revised to address comments from the Onsite Safety Review Committee (OSRC) review on1/13/15.This evaluation addresses the retirement of the Emergency Response Data System (ERDS) and removal of ERDS fromthe 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," andAP-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 TechnicalRequirements Manual (TRM) (Rev. 53) were searched for the following keywords: Emergency Response Data Systemand ERDS. Additionally, EPOP-TSC-3542, "Operation of the Technical Support Center," EPOP-EOF-3546, "EmergencyOperations 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 DataSystem 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 forreferences to ERDS and no results were found.ERDS was identified in the following:Emergencv PlanAccording to Section 7.10 of the VY Emergency Plan, "ERDS is a direct real-time electronic transmission of the followingtypes 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 acontinuous ERDS connection with the NRC Operations Center."UFSARSection 7.15.1 of the UFSAR (Rev. 26) states that the Process Computer System (PCS) exports data to an EmergencyResponse Data System (ERDS) function and that, once activated, EROS sends selected current plant data points to theNRC Operations Center on a periodic basis. Section 7.15.2, Item #4 states that the PCS data export feature shall supportthe following ERDS functions (resident on another system): Capable of being manually activated within one hour; Onceactivated, will establish data communications with the NRC ERDS computer system,; Transmit critical plant data in theproper format and protocol at time Intervals of not less than 15 seconds or more than 60 seconds, until the link ismanually disconnected, and; If the data connection is lost, the ERDS Interface module is responsible for re-establishingcommunication with the ERDS computer.EPOP-TSC-3542Step 1.2 of Attachment 2 of EPOP-TSC-3542 states that the TSC Manager is responsible for ensuring the IT Specialisthas verified the ERDS connection. Step 1.2 of Attachment 12 instructs the IT Specialist to verify the EROS connection perEN-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 initialdeclaration 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 Specialistis unable to verify the connection within the required time, then one of the following (in this order) will perform theverification: 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 VermontEN-EP-305 REV 3 Ar"FACHMENT 9.210CFR50.54(q) EvALuATiONProcedure/Document Number: NA Revision: NAPage 2 of 7Equipment/FacllitylOther: Vermont Yankee ERDSTitle: NAYankee maintains a continuous connection to the NRC.EPOP-EOF-3546Step 1.2 of Attachment 6 of EPOP-EOF-3546 instructs the Offsite Communicator to confirm that the IT Specialist hasverified the ERDS connection with the NRC and to follow the Instructions in EN-EP-31 1 to perform the verification if the ITSpecialist has not already performed the verification. Step 3.1 of Attachment 6 of EPOP-EOF-3546 instructs the OffsiteCommunicator 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 initialdeclaration 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 SpecialistIs unable to verify the connection within the required time, then one of the following (in this order) will perform theverification: 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 byinterpreting information/data, if necessary, for use with NRC ERDS, METPAC, Rascal and any other computer systemsused for radiological assessment. The New Hampshire and Massachusetts Offsite Liaisons mobilize to the StateEmergency Operations Centers (EOCs). The Vermont Offsite Liaison is stationed at the EOF.EN-EP-311EN-EP-311 provides for a secure network communications connection supporting the transmission of station parametersto the NRC in the event of a declared emergency. The procedure provides the methodology for establishing the VirtualPrivate Network (VPN) communications link to the NRC for the transmission of ERDS data. The procedure also providesinstructions for verification of connections for those Entergy plants which maintain 24/7 connectivity.EPAD-0093Attachment 4 of EPAD-0093 contains instructions for ensuring that the NRC is notified prior to a drill or exercise in whichERDS will be used and Attachment 10 contains actions taken following a drill or exercise with respect to restoration ofERDS.AP-1.0049AP-10049 identifies ERDS as equipment important to emergency response. ERDS Is described as "a direct real timeelectronic 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 PreparednessRegulation(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 NRCcommitments (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 principalresponse organizations to emergency personnel and to the public.Site Compliance: Section 7.0 of the Emergency Plan and EPOP-COMM-3504 describe the available communicationsequipment, the location of this equipment, and the procedures for communicating with on-site and off-site support groupsincluding 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 theability of the States to access ERDS for the provision of data. VY maintains the ability to provide data to the ERO andState Representatives in the EOF. The data is available in the EOF via the Plant Display System (PDS). This data willcontinue to be available to State Representatives in the EOF via the display screens. If requested by the States, theinformation 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 9.210CFR50.54(q) EVALUATIONProcedure/Document Number: NA Revision: NAPage 3 of 7EquipmentlFacllity/Other: Vermont Yankee ERDSTitle: NA10 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'sonsite computer system and the NRC Operations Center that provides for the automated transmission of a limited dataset of selected parameters. The ERDS supplements the existing voice transmission over the Emergency NotificationSystem (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parametersfrom the licensee's installed onsite computer system in the event of an emergency. When selected plant data are notavailable on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shall test theERDS periodically to verify system availability and operability. The frequency of ERDS testing will be quarterly unlessotherwise 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, onsitehardware shall be provided at each unit by the licensee to Interface with the NRC receiving system. Software, which willbe made available by the NRC, will assemble the data to be transmitted and transmit data from each unit via an outputport 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 plantmeteorological tower data. A separate data feed is required for each reactor unit. While It Is recognized that ERDS is nota 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 parameterswill 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 coolantcharging/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) Safetyinjection: High- and low-pressure safety Injection flows, safety injection flows (Westinghouse), and borated water storagetank level; (4) Containment: pressure, temperatures, hydrogen concentration, and sump levels; (5) Radiation monitoringsystem: Reactor coolant radioactivity, containment radiation level, condenser air removal radiation level, effluent radiationmonitors, and process radiation monitor levels; and (6) Meteorological data: wind speed, wind direction, and atmosphericstability.(ii) For boiling water reactors (BWRs), the selected parameters are: (1) Reactor coolant system: Reactor pressure, reactorvessel level, feedwater flow, and reactor power; (2) Safety injection: Reactor core isolation cooling flow, high-pressurecoolant injection/high-pressure core spray flow, core spray flow, low-pressure coolant injection flow, and condensatestorage tank level; (3) Containment: drywell pressure, drywell temperatures, dtywell sump levels, hydrogen and oxygenconcentrations, suppression pool temperature, and suppression pool level; (4) Radiation monitoring system: Reactorcoolant radioactivity level, primary containment radiation level, condenser off-gas radiation level, effluent radiationmonitor, 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 15seconds 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# asconfigured 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 changesare completed.b. Hardware and software changes, with the exception of data point modifications, that could affect the transmissionformat and computer communication protocol to the ERDS must be provided to the NRC as soon as practicable and atleast 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 forlicensee 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. ToEN-EP-305 REV 3 ATTACHMENT 9.210CFR50.54(q) EVALuATiONProcedure/Document Number: NA Revision: NAPage 4 of 7EquipmentlFacliity/Other: Vermont Yankee ERDSTitle: NAensure 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 berequired 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 fullpower, whichever comes later. Licensees with currently operational EROS interfaces approved under the voluntary ERDSimplementation program will not be required to submit another Implementation plan and will be considered to have metthe 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 SupportCenter," EPOP-EOF-3546, "Emergency Operations Facility/Recovery Center (EOF/RC)," VY currently maintains acontinuous 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 whohave submitted a certificate of permanent cessation of operation of a nuclear power facility. Per NRC memoranda dated6/2/14 (ML14099A520), the objective of ERDS, since its inception, has been to facilitate NRC monitoring of licenseeresponse 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 permanentremoval 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 50license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vesseland the requirements for ERDS in 10 CFR 50 Appendix E section VI.2 will no longer apply. Because Section VI ofAppendix E to 10 CFR Part 50 is not applicable to permanently shutdown facilities, the emergency plan, as modified, willcontinue to meet the applicable requirements.10 CFR 50.72(a)(4) -ERDS Activation: The licensee shaft activate the Emergency Response Data System (ERDS) assoon as possible but not later than one hour after declaring an Emergency Class of alert, site area emergency, or generalemergency. The ERDS may also be activated by the licensee during emergency drills or exercises if the licensee'scomputer 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 toERDS, an initial verification of the ERDS connection with the NRC following declaration of an emergency is currentlyperformed 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 DepartmentPersonnel. Because ERDS requirements are not applicable to facilities which have permanently ceased operations, therecan be no required ERDS for such a facility to activate and the emergency plan, as modified, will continue to meet theapplicable requirements.10 CFR 50.72(c)(3) -Continuous Communication: Maintain an open, continuous communication channel with the NRCOperations 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 OperationsCenter 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, withextensions in the Communications Room and the NRC Room of the TSC. The ENS also utilizes a separate FTS linebetween 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 ElementsAffected by the Proposed Change:1A C FR ~F;l d7(h'(R'h -(t~nmmt~nipntinn~lo cFR -rn 47(b)[A) -Ems-ency CommunicationsEN-EP-305 REV 3 ArrAcHMENT 9.210CFR50.54(q) EvALuATIONProcedure/Document Number: NA Revision: NAPage 5 of7 IEqulpmentfFacilitylOther: Vermont Yankee ERDSTitle: 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 ofNUREG-0654 and the licensee's emergency plan.Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency PlanFunctions:Regulatory Guide 1.219, "Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors" providesguidance 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 planrequires prior NRC approval. First, the test assesses whether the emergency plan, as modified, would continue to complywith the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR Part 50. Second, the testassesses whether the proposed change would reduce the effectiveness of the emergency plan. These two tests areseparate and distinct. If the licensee does not meet either test, it must obtain prior NRC approval. Meeting the first testdoes not imply that the licensee has met the second test, nor does meeting the second test imply that the licensee hasmet 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 toemergency personnel and to the publlc.The VY Emergency Plan does not rely upon ERDS for transmission of informationor data to the State or local authorities or to the public. Section 7.0 of the emergency plan Identifies the means ofcommunication with State and local authorities. This is accomplished via InForm, Nuclear Alert System, Mobile UHFRadio System, commercial telephone system, and facsimile. ERDS is not identified as a communication channel to Stateresponse organizations; it Is one of the communication channels between VY and the NRC. Therefore, the removal ofERDS from the Emergency Plan would not affect the ability of VY to maintain prompt communication among principalresponse organizations, to emergency personnel, and to the public. Additionally, data Is available in the EOF via thePDS. This data will continue to be available to State Representatives In the EOF via the display screens. If requested bythe States, the information could also be provided to the State EOCs by VY administrative personnel in the EOF via emailor 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 permanentremoval 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 50license 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 forProduction and Utilization Facilities,"Section VI, "Emergency Response Data System."Section VI(2) provides anexclusion for reactors that are permanently or indefinitely shut down. In the Statements of Consideration (SOC) for theERDS final rule (50 Federal Register 50178, August 13, 1991) the NRC stated the objective of the rule was to provide areliable and effective communication system that would allow the NRC to monitor critical parameters at operating reactorsduring an emergency. The NRC Identified that it has a responsibility in the event of a reactor accident to monitor theactions of the licensee and to promptly assess the situation at the plant. The NRC described ERDS as a supplement tothe 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 powerreactor 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 theprovisions 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 allapplicable 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. radiationEN-EP-305 REV 3 ATTACHMENT 9.210CFR50.54(q) EvALUATIONProcedure/Document Number: NA Revision: NAPage 6 of 7Equlpment/Facility/Other: Vermont Yankee ERDSTitle: NAmonitoring data, reactor building pressure data, torus water level data and meteorological data. While some of thisinformation could be used for emergency dose assessment and determination of public protective actionrecommendations, VY does not rely on ERDS for the provision of this data to the VY Emergency Response Facilities, theVY Emergency Response Organization (ERO), or to the offsite agencies. VY provides this plant data to the offsiteauthorities via numerous other means. The data is available in the EOF via the PDS. This data will continue to beavailable to State Representatives in the EOF via the display screens. If requested by the States, the information couldalso 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 theEmergency Operations Facility (EOF), Technical Support Center (TSC) and Operations Support Center (OSC) via theEmergency Response Facilities Information System (ERFIS) and PDS screens in each facility. Therefore, the retirementof 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 plantcomputer system or directly from Control Room instrumentation, both of which remain available to the VY ERO In theTSC and the EOF. Similarly, the plant computer system and Control Room instrumentation will remain available to theon-shift staff. Therefore, the retirement of ERDS would not reduce the effectiveness of VY's ability to communicate plantinformation 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, VYprovides plant data to State personnel stationed at the EOF or at their respective EOCs. The data is available in theEOF, TSC and OSC via the PDS. This data would be available to ERO and State personnel in the EOF, TSC and OSCvia the display screens. The VY Vermont Offsite Liaison is stationed at the EOF. The VY New Hampshire andMassachusetts Offsite Liaisons mobilize to the State Emergency Operations Centers (EOCs). EPOP-EOF-3546 instructsthe 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 arealso maintained in the Post-Shutdown ERO and will continue to assist State personnel by interpreting information/datafrom the plant computer system. Consequently, retirement of ERDS would not reduce the effectiveness of VY's ability tocommunicate plant data to State response organizations.NRC guidance dated 6/2/14 (ML14099A520) confirms that removing ERDS would not reduce the effectiveness of alicensee's emergency plan:'...the objective of ERDS, since its inception, has been to facilitate NRC monitoring of licenseeresponse to the event and NRC assessment of the situation at the plant. Providing ERDS data tothe NRC is not an emergency planning function as defined In 10 CFR 50.54(q)(1)(iil). Because areduction in effectiveness requires a reduction of the licensee's capability to perform an emergencyplanning function and providing data to the NRC through ERDS is not an emergency planningfunction, removing ERDS would not reduce the effectiveness of the licensee's capability to performan emergency planning function. Accordingly, removing ERDS would not reduce the effectivenessof 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 10CFR 50.47(b)(6), 50.72(c)(3), and the remaining applicable requirements of Appendix E to 10 CFR Part 50. Removal ofERDS does not represent a reduction in effectiveness to the Emergency Plan and can be implemented without prior NRCapproval.Part VI. Evaluation ConclusionAnswer 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 NO2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in IOYES [I NOeffectiveness)?3. Does the proposed change constitute an emergency action level scheme change? []YES 0 NOIf questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposedchange and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50,90. If questions 1 andEN-EP-305 REV 3 ATTACHMENT 9.210CFR50.54(q) EVALUATIONProcedure/Document Number: NA Revision: NAPage 7 of 7Equipment/FacilityiOther: Vermont Yankee ERDSTitle: NA2 are answered YES, and question 3 answered NO, implement applicable change process(es). Refer to step 5.6[8].Part VII. SignaturesPreparer Name (Print) Preparer Signature Date:01/22/2015David L. Daigle ký 4 7 0,20(Optional) Reviewer Name (Print) Reviewer Signature Date:Reviewer Name (Print) Reviewer Signature Date:Tom Sowdon ... 1-26-2015Nuclear EP Project ManagerApproiPal ?6aney A prover Pigg wre Date:EP Manager or designee 1 IA/EN-EP-305 REV 3