ML15079A422

Entergy Answer Opposing State Appeal - Vermont Yankee Nuclear Power Station - Emergency Plan Change, Revision 55

ML15079A422
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
SECY RAS
Shared Package
ML15079A421	List: BVY 15-003, Entergy Answer Opposing State Appeal - Vermont Yankee Nuclear Power Station - Emergency Plan Change, Revision 55 ML15079A423
References
50-271-LA, ASLBP 15-934-01-LA- BD01, BVY 15-003, RAS 27403
Download: ML15079A422 (111)

Text

• *-w-. Entergy BVY 15-003 February 23, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Emergency Plan Change, Revision 55 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28 Entergy Nuclear Operations, Inc . Vermont Yankee P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 258 4183 Michael P. McKenney Emergency Planning Manager

REFERENCE:

Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station -Issuance of Amendment to Renewed Facility Operating License RE: Changes to the Emergency Plan {TAC NO. MF3668,)" dated February 4, 2015

Dear Sir or Madam:

In accordance with 10 CFR 50.54(q) Entergy Nuclear Operations, Inc. is providing Revision 55 of the Vermont Yankee Nuclear Power Station Emergency Plan (Plan) as an attachment to this letter. This revision of the Plan incorporates changes approved by the NRC in Reference 1. This revision also includes several changes that were evaluated pursuant to 10 CFR 50.54{q)(3) that were determined not to require prior NRC approval. Included with this revision is a description of the changes and the 10 CFR 50.54(q) Screening and Evaluation Forms for those changes performed pursuant to 10 CFR 50.54(q)(3). There are no new regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact me at 802-258-4183. Sincerely, BVY 15-003/ Page 2 of 2

Attachment:

Emergency Plan Change, Revision 55 cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd. Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street -Drawer 20 Montpelier, Vermont 05620-2601 Vermont Yankee Nuclear Power Station Emergency Plan Change, Revision 55 BVY 15-003 Docket No. 50-271 ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 1 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan): On 9/23/13, Entergy Vermont Yankee notified the NRC by letter BVY 13-079 of the decision to permanently cease power operations in the 4th quarter of 2014.This letter acknowledges that the Vermont Yankee 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel after the end of the operating cycle. The changes to the VY Emergency Plan reflect the permanently defueled condition of VY. Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). These changes were approved by the NRC upon issuance of License Amendment 261. (Change summary attached) The Emergency Plan and the following documents have been revised to incorporate the approved License Amendment for the SAFSTOR Emergency Plan and Emergency Response Organization (ERO). See attached change summaries for each document. Cancel V-EN-TQ-110, Emergency Response Organization, Rev 11 and V-EN-TQ-110-01, Fleet Eplan Training Course Summary, Rev 2 to the SAFSTOR Emergency Planning Training Program Description EPOP-TSC-3542, Operation of the Technical Support Center (TSC), Rev 02 EPOP-OSC-3544, Operation of the Operations Support Center (OSC), Rev 01 EPOP-EOF-3546, Emergency Operations Facility/Recovery Center (EOF/RC), Rev 03 EPOP-JIC-3550, Activation and Operation of the Joint Information Center, Rev 01 EPOP-3551, Operation of the Joint Information Center when the Alternate Joint Information Center is Activated, Rev 01 EPOP-3552, Activation and Operation of the Alternate Joint Information Center, Rev 01 V-EN-EP-801, Emergency Response Organization AP 0894, Staffing Limits Part II. Activity Previously Reviewed? Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report? If YES, identify bounding source document number/approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below: YES 50.54(q)(3) Evaluation is NOT required. Enter justification below and complete Part VI. NO Continue to next part Justification: Changes involving a reduction in the minimum on-shift and emergency response organization (ERO) staffing were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). These changes were approved by the NRC upon issuance of License Amendment 261. No further evaluation required. Bounding document attached (optional)

References:

BVY 13-079; BVY 14-018 ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 2 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 Part III. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-100) NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3) Screening. APPLICABILITY CONCLUSION If there are no controlling change processes, continue the 50.54(q)(3) Screening. One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below. One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3) Evaluation is NOT required. Identify controlling change processes below and complete Part VI. CONTROLLING CHANGE PROCESSES 10CFR50.54(q) Part IV. Editorial Change Is this activity an editorial or typographical change such as formatting, paragraph numbering, spelling, or punctuation that does not change intent? Justification: YES 50.54(q)(3) Evaluation is NOT required.

Enter justification and complete Part VI. NO Continue to next part Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? 1. Responsibility for emergency response is assigned. [1] 2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan. [1] 3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] 4. The process for timely augmentation of onshift staff is established and maintained. [2] 5. Arrangements for requesting and using off site assistance have been made. [3] 6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] 7. A standard scheme of emergency classification and action levels is in use. [4] 8. Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5] 9. Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. [5] 10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5] 11. Systems are established for prompt communication among principal emergency response organizations. [6]

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 3 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 12. Systems are established for prompt communication to emergency response personnel. [6] 13. Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). [7] 14. Coordinated dissemination of public information during emergencies is established. [7] 15. Adequate facilities are maintained to support emergency response. [8] 16. Adequate equipment is maintained to support emergency response. [8] 17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] 18. A range of public PARs is available for implementation during emergencies. [10] 19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. [10] 20. A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.[10] 21. The resources for controlling radiological exposures for emergency workers are established. [11] 22. Arrangements are made for medical services for contaminated, injured individuals. [12] 23. Plans for recovery and reentry are developed. [13] 24. A drill and exercise program (including radiological, medical, health physics and other program areas) is established. [14] 25. Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14] 26. Identified weaknesses are corrected. [14] 27. Training is provided to emergency responders. [15] 28. Responsibility for emergency plan development and review is established. [16] 29. Planners responsible for emergency plan development and maintenance are properly trained. [16]

ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 4 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 APPLICABILITY CONCLUSION If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI. If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation. BASIS FOR CONCLUSION Part VI. Signatures: Preparer Name (Print) Justine Anderson Preparer Signature Date: 2/4/15 (Optional) Reviewer Name (Print) Reviewer Signature Date: Reviewer Name (Print) Tom Sowdon Nuclear EP Project Manager Reviewer Signature Date: 2/4/15 ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 5 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 Emergency Planning Training Program Description Developed training for new SAFSTOR organization to match the staffing changes in BVY 14-018 EPOP-TSC-3542, Operation of the Technical Support Center (TSC), Rev 02 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: TSC Manager Reactor Engineer Manpower and Planning Liaison TSC Communicator TSC Engineer IT Specialist EPOP-OSC-3544, Operation of the Operations Support Center (OSC), Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: Operations Support I&C/Electrical Coordinator Mechanical Coordinator Rad/Chem Coordinator Work Control Coordinator OSC Log Keeper EPOP-EOF-3546, Emergency Operations Facility/Recovery Center (EOF/RC), Rev 03 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: EOF Manager EOF Communicator Public Information Liaison Emergency Planning Coordinator IT Specialist EOF Log Keeper EPOP-JIC-3550, Activation and Operation of the Joint Information Center, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: Information Coordinator Press Release Writer Logistics Coordinator Technical Assistant JIC Log Keeper Inquiry Response Coordinator Media Monitor/Status Phone Recorder Credentialing ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 6 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 EPOP-3551, Operation of the Joint Information Center when the Alternate Joint Information Center is Activated, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: Information Coordinator Press Release Writer Logistics Coordinator Technical Assistant Inquiry Response Coordinator Media Monitor/Status Phone Recorder EPOP-3552, Activation and Operation of the Alternate Joint Information Center, Rev 01 Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: Logistics Coordinator Credentialing JIC Log Keeper V-EN-EP-801, Emergency Response Organization Updated procedure to match the post-shutdown Emergency Response Organization, including deletion of the following positions: TSC Manager Reactor Engineer Manpower and Planning Liaison TSC Communicator TSC Engineer IT Specialist Operations Support I&C/Electrical Coordinator Mechanical Coordinator Rad/Chem Coordinator Work Control Coordinator OSC Log Keeper EOF Manager EOF Communicator Public Information Liaison Emergency Planning Coordinator IT Specialist EOF Log Keeper Information Coordinator Press Release Writer Logistics Coordinator Technical Assistant JIC Log Keeper Inquiry Response Coordinator Media Monitor/Status Phone Recorder Credentialing Removed all information pertaining to other Entergy sites ATTACHMENT 9.1 10CFR50.54(q) SCREENING PAGE 7 OF 7 Procedure/Document Number: Emergency Plan & Emergency Plan Implementing Procedures Revision: Various Equipment/Facility/Other: Vermont Yankee Title: Emergency Plan & Emergency Plan Implementing Procedures (Listed below under Part I) EN-EP-305 REV 3 AP 0894, Staffing Limits Revised on shift staffing to match the License Amendment 261 from the NRC ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE1 OF52EN-LI-100 REV. 16I. OVERVIEWPAD 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 staffing levels approved by License Amendment 261 include: Table 8.4, "Minimum Staffing Requirements for the ENVY ERO" Table 8.3, "A Summary of Off-site Coordination" Figure 8.2, "VY Emergency Management Organization" Figure 8.3, "Technical Support Center Emergency Organization" Figure 8.4, "Operations Support Center Emergency Organization" Figure 8.5, "Emergency Operations Facility Organization" Figure 8.7, "Joint Information Center Organization" Table 9.1, "Vermont Yankee Emergency Response"All other changes to reflect a permanently defueled facility were performed under the 10CFR50.54(q)process.II.DOCUMENT 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 Response Data 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 document ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE2 OF52EN-LI-100 REV. 162.Documents reviewed manually (hardcopy):Emergency Plan: Figure 4.1, 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, 4.8, 6.1, 6.2, 6.3, 6.4, 7.1, 7.2, 8.1,8.2, 8.3, 8.4, 8.5, 8.7, 9.1, 10.1, 10.2 & 10.33. 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 as needed. Document below the extent to which the Attachment 9.2 questions were used.For LBDs not searched electronically or manually the questions in Attachment 9.2 werereviewed and no LBD changes were identified.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE3 OF52EN-LI-100 REV. 16III.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 / Procedures)YESNOREVIEW RESULTSChemistry / EffluentsRadwaste / Process Control Program (PCP)(EN-RW-105 or contact the Radiation Protection Dept.)Radiation Protection / ALARA (10 CFR 20 / EN-RP-110 or contact the Radiation Protection Dept.)Inservice Inspection Program(10 CFR 50.55a / EN-DC-120, -351)Inservice Testing Program(10 CFR 50.55a / EN-DC-332)Maintenance Rule Program(10 CFR 50.65 / EN-DC-203, -204, -205, -206,-207)Containment Leakage Rate Testing (Appendix J) Program(10 CFR 50Appendix J / EN-DC-334)PROCESS (Regulations/Procedures)YESNON/AREVIEW RESULTSFlex Program (NRC Order EA-12-49/FLEX Program)(10CFR50.59/Contact 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-12-49. 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.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE4 OF52EN-LI-100 REV. 16IV.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 Basis Document below.LICENSING BASIS DOCUMENTS(Regulations / Procedures)YESNOREVIEW RESULTS OR SECTIONSAFFECTED OR LBDCR #Quality Assurance Program Manual (QAPM)(10 CFR 50.54(a) / EN-QV-104)Fire Protection Program (FPP) [includes the Fire Safety Analysis/FireHazards Analysis (FSA/FHA)]OL Condition, 10 CFR 50.48 / EN-DC-128)Emergency Plan(10 CFR 50.54(q) / EN-EP-305)Screened IAW EN-EP-305Environmental Protection Plan(Appendix B of the OL, Environmental Evaluation / EN-EV-115, EN-EV-117,EN-LI-103)No EPP at VYSecurity Plan and Cyber Security Plan[10 CFR 50.54(p) / EN-NS-210 or contact the site Security / IT Dept.]Operating License (OL) / Technical Specifications (TS)(10 CFR 50.90 / EN-LI-103)*TS Bases(10 CFR 50.59 / EN-LI-100 / EN-LI-101)Technical Requirements Manual (TRM) (including TRM Bases)(10 CFR 50.59 / EN-LI-100 / EN-LI-101)Core Operating Limits Report (COLR), and Pressure and Temperature Limits Report (PTLR) (TS Administrative Controls, EN-LI-113, EN-LI-100,EN-LI-101)Offsite Dose Calculation Manual (ODCM)(TS Administrative Controls or 10 CFR 50.59 / EN-LI-113 or EN-LI-100 /EN-LI-101)Updated Final Safety Analysis Report (UFSAR)(10 CFR 50.71(e) / EN-LI-113, EN-LI-100, EN-LI-101)UFSAR markups to reflect terminationof the Emergency Response DataSystem have been submitted toLicensingStorage Cask Certificate of Compliance(10 CFR 72.244 / EN-LI-113)*Cask FSAR (CFSAR) (including the CTS Bases)(10 CFR 72.70 or 72.248 / EN-LI-113, EN-LI-100,EN-LI-112)10 CFR 72.212 Evaluation Report (212 Report)

(10 CFR 72.48 / EN-LI-100, EN-LI-112)NRC Orders(10 CFR 50.90 / EN-LI-103 or as directed by the Order)*NRC Commitments and Obligations(EN-LI-110)*Site Specific CFR Exemption(10 CFR 50.12, 10 CFR 55.11, 10 CFR 55.13, 10 CFR 72.7)**Contact the site Regulatory Assurance Department if needed.IF any box is checked "Yes," THEN ensure that any required regulatory reviews are performed 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 #. Briefly discuss how the LBD is affected in Section VII.A.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE5 OF52EN-LI-100 REV. 16V.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).An approved, valid 50.59/72.48 Evaluation covering associated aspects of the proposed activity already exists. Reference 50.59/72.48 Evaluation # _________________ (if applicable) or attach documentation. Verify the previous 50.59/72.48 Evaluation 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 approval document: Licensing Amendment 261The 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 VII.A.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 1 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]

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE6 OF52EN-LI-100 REV. 16VI.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 SCREENING10 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; ANDDoes not adversely affect a method of performing or controlling a design function of an SSC asdescribed in the UFSAR; ANDDoes not adversely affect a method of evaluation that demonstrates intended design function(s) ofan SSC will be accomplished as described in the UFSAR; ANDDoes 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 a50.59 Evaluation in accordance with EN-LI-101, attach a copy of the Evaluation to this form, andproceed to Section VII.VI.B 72.48 SCREENING10 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; ANDDoes not adversely affect a method of performing or controlling a design function of an SSC asdescribed in the CFSAR; ANDDoes not adversely affect a method of evaluation that demonstrates intended design function(s) ofan SSC will be accomplished as described in the CFSAR; ANDDoes 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, THENperform a 72.48 Evaluation in accordance with EN-LI-112, attach a copy of the Evaluation to thisform, and proceed to Section VII.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE7 OF52EN-LI-100 REV. 16VI.B BASISProvide 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 supporting documentation or references as appropriate.VII. 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 were submitted to the NRC for review and approval under a license amendment (Ref: BVY 14-018). These changes were approved by the NRC upon issuance of License Amendment 261. No additional evaluation is required for these changes.Other changes to the Emergency Plan to reflect the permanently defueled condition are evaluatedpursuant to 10 CFR 50.54(q) in accordance with EN-EP-305.VII.BCONCLUSIONS1.Is a change to an LBD being initiated?YesIF"Yes,"THENenter the appropriate change control process and includethis form with the change package. (LBDCR LIC 14-14)No2.Is a 10 CFR 50.59 Evaluation required?YesIF"Yes,"THENcomplete a 50.59 Evaluation in accordance with EN-LI-101and attach a copy to the change activity.No3.Is a 10 CFR 72.48 Evaluation required?YesIF"Yes,"THENcomplete a 72.48 Evaluation in accordance with EN-LI-112and attach a copy to the change activity.No ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE8 OF52EN-LI-100 REV. 16VIII.SIGNATURES1Preparer:Justine Anderson/ /ENVY/ Eplan/ 1/16/15Name (print) / Signature / Company / Department / DateReviewer:Phil Couture/ Approved per telecon /ENVY/ Licensing/ 2/4/15Name (print) / Signature / Company /Department / DateProcess Applicability ExclusionSite ProcedureN/AChampion orOwner:Name (print) / Signature / Company / Department / DateUpon 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.1The 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.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE9 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeTable of Contents--Updated page numbers andSection headings to reflectchanges described below,including updated page numbers and deletion of Section 6.2.5 (Post Accident Sampling) andSection 7.10 (EmergencyResponse Data System).Editorial revision to reflectchanges described below,including updated pagenumbers and deletion of Section 6.2.5 (Post Accident Sampling) and Section 7.10(Emergency Response DataSystem).Table of Contents -AppendicesAppendix C Initial Offsite DoseRate Estimate(Deleted)VY will no longer be anoperating nuclear powerplant. Appendix C is no longer applicable because it is based on the isotopic mixfor a Loss of CoolantAccident (LOCA).Table of Contents - List ofFiguresFigure 8.1Normal On-ShiftEmergency OrganizationFigure 8.1Defueled On-ShiftEmergency OrganizationVY will no longer be anoperating nuclear powerplant. The title change reflects the permanently defueled organizationalstructure.Table of Contents - List ofFiguresFigure 8.2Vermont YankeeEmergency ManagementOrganizationFigure 8.2Vermont YankeeDefueled EmergencyManagement OrganizationVY will no longer be anoperating nuclear powerplant. The title changereflects the permanently defueled organizational structure.Table of Contents - List of FiguresFigure 8.3Technical SupportCenter Emergency OrganizationFigure 8.3DefueledTechnical Support Center Emergency OrganizationVY will no longer be anoperating nuclear power plant. The title changereflects the permanentlydefueled organizational ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE10 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changestructure.Table of Contents - List ofFiguresFigure 8.4OperationsSupport Center Emergency Organization(Deleted)ERO Staffing changes resultin one remaining OSC position (OSC Manager) illustrated on the figure. Afigure is no longernecessary to describe the OSC organization.Table of Contents - List of FiguresFigure 8.5EmergencyOperations Facility OrganizationFigure 8.5DefueledEmergency Operations Facility OrganizationVY will no longer be anoperating nuclear power plant. The title change reflects the permanentlydefueled organizationalstructure.Table of Contents - List ofFiguresFigure 8.7Joint InformationCenter OrganizationFigure 8.7Defueled JointInformation Center OrganizationVY will no longer be anoperating nuclear powerplant. The title change reflects the permanently defueled organizationalstructure.Table of Contents - List ofFiguresFigure 10.1 Vermont YankeeEmergency Dose RateNomogram(Deleted)VY will no longer be anoperating nuclear powerplant. Figure 10.1 is nolonger applicable because it is based on the isotopic mix for a LOCA.Section 2.0 - Definition of AlertAlert-Events are in process orhave occurred which involve anactual or potential substantialdegradation of the level of safetyof the plant or a security event that involves probable life threatening risk to site personnelAlert-Events are in progress orhave occurred which involve anactual or potential substantialdegradation of the level of safetyof the plant or a security event that involves probable life threatening risk to site personnelEditorial revision to reflectdefinition in NEI 99-01, Rev.

5 ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE11 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeor damage to site equipmentbecause of HOSTILE ACTION.Any releases are expected to be limited to small fractions of theEPA Protective Action Guidelineexposure levels.or damage to site equipmentbecause of HOSTILE ACTION.Any releases are expected to be limited to small fractions of theEPA Protective Action Guidelineexposure levels.Section 2.0 - Definition of Assessment ActionsAssessment Actions-Thoseactions which are take toeffectively define the emergencysituation necessary for decisions on specific emergencymeasures.Assessment Actions-Thoseactions which are taken toeffectively define the emergencysituation necessary for decisions on specific emergencymeasures.Editorial revision to correctgrammatical errorSection 2.0 - Definition of General EmergencyGeneral Emergency-Eventsare in process or have occurredwhich involve actual or imminentsubstantial core degradation ormelting with potential for loss of containment integrity orHOSTILE ACTION that results inan actual loss of physical control of the facility. Releases can be reasonably expected to exceedEPA Protective Action Guidelineexposure levels offsite for more than the immediate site area.General Emergency-Eventsare in progress or have occurredwhich involve actual or imminentsubstantial core degradation ormelting with potential for loss of containment integrity orHOSTILE ACTION that results inan actual loss of physical control of the facility. Releases can be reasonably expected to exceedEPA Protective Action Guidelineexposure levels offsite for more than the immediate site area.Editorial revision to reflectdefinition in NEI 99-01, Rev.

5Section 2.0 - Definition ofHostile ActionHostile Action-An act towardan NPP or its personnel thatincludes the use of violent force to destroy equipment, takeshostages, and/or intimidates thelicensee to achieve an end. This includes attack by air, land, orwater using guns, explosives,projectiles, vehicles, or otherHostile Action-An act towardan NPP or its personnel thatincludes the use of violent force to destroy equipment, takeshostages, and/or intimidate thelicensee to achieve an end. This includes attack by air, land, orwater using guns, explosives,projectiles, vehicles, or otherEditorial revision to reflectdefinition in NEI 99-01, Rev.5 ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE12 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changedevices used to deliverdestructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTIONshould not be construed toinclude acts of civil disobedience or felonious acts that are not part of a concerted attack on theNPP. Non-terrorism-based EALsshould be used to address such activities, (e.g., violent actsbetween individuals in the ownercontrolled area).devices used to deliverdestructive force. Other acts thatsatisfy the overall intent may be included. HOSTILE ACTIONshould not be construed toinclude acts of civil disobedience or felonious acts that are not part of a concerted attack on theNPP. Non-terrorism-based EALsshould be used to address such activities, (e.g., violent actsbetween individuals in the ownercontrolled area).Section 2.0 - Definition of Notification of Unusual EventNotification of Unusual Event- Events are in process or haveoccurred which indicate apotential degradation of the level of safety of the plant or indicatea security threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite response ormonitoring are expected unlessfurther degradation of safety systems occurs.Notification of Unusual Event- Events are in progress or haveoccurred which indicate apotential degradation of the level of safety of the plant or indicate asecurity threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite response ormonitoring are expected unlessfurther degradation of safety systems occurs.Editorial revision to reflectdefinition in NEI 99-01, Rev.5Section 2.0 - Definition ofSite Area EmergencySite Area Emergency-Eventsare in process or have occurredwhich involve an actual or likely major failures of plant functionsneeded for protection of thepublic or HOSTILE ACTION that results in intentional damage ormalicious acts; (1) toward sitepersonnel or equipment thatSite Area Emergency-Eventsare in progress or have occurredwhich involve an actual or likely major failures of plant functionsneeded for protection of thepublic or HOSTILE ACTION that results in intentional damage ormalicious acts; (1) toward sitepersonnel or equipment thatEditorial revision to reflectdefinition in NEI 99-01, Rev.

5 ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE13 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changecould lead to the likely failure ofor; (2) that prevent effectiveaccess to equipment needed for the protection of the public. Anyreleases are not expected toresult in exposure levels which exceed EPA Protective Action Guideline exposure levelsbeyond the site boundary.could lead to the likely failure ofor; (2) that prevent effectiveaccess to equipment needed for the protection of the public. Anyreleases are not expected toresult in exposure levels which exceed EPA Protective Action Guideline exposure levelsbeyond the site boundary.Section 3.2 - 1st Paragraph,Item 55) Notify state authorities inVermont, New Hampshire andMassachusetts using theEmergency Notification System.5) Notify state authorities inVermont, New Hampshire andMassachusetts using the InFormNotification System.InForm added to theEmergency Plan in Rev. 54.Section 3.2 - 1st Paragraph,Item 77) Use the emergencynotification system to notifyappropriate personnel as setforth in Figure 9.1 and Table 9.1.7) Use the notification plan tonotify appropriate personnel asset forth in Figure 9.1 and Table9.1.The Emergency NotificationSystem is a formal systemused to notify the NRCduring an emergency. The generic use of "emergencynotification system" in Step7 can be confusing and is meant only to direct the communicator to use thenotification plan set forth inFigure 9.1 and Table 9.1 of the Emergency Plan and notthe Emergency NotificationSystem. Figure 9.1 is entitled "Notification Plan" and identifies the methodsused to notify various offsiteagencies.Section 4.1Vermont Yankee Nuclear PowerStation is located on the westbank of the Connecticut RiverVermont Yankee Nuclear PowerStation is located on the westbank of the Connecticut RiverVY will no longer be anoperating nuclear powerplant. The Site Description ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE14 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeimmediately upstream of theVernon Hydrostation, in the townof Vernon, Vermont. The Vermont Yankee Nuclear PowerStation is a boiling water reactorhaving a thermal rated power of 1912 MWt. The station, shown in Figure 4.1, is located on about125 acres in Windham County,and is owned by Entergy, with the exception of a narrow strip ofland between the ConnecticutRiver and the Vermont Yankee property for which it has perpetual rights and easementsfrom the owner, New EnglandPower Company.immediately upstream of theVernon Hydrostation, in the townof Vernon, Vermont. The Vermont Yankee Nuclear PowerStation ceased power operationsand is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). Thestation, shown in Figure 4.1, islocated on about 125 acres in Windham County, and is ownedby Entergy, with the exception ofa narrow strip of land between the Connecticut River and the Vermont Yankee property forwhich it has perpetual rights andeasements from the owner, New England Power Company.On January 12, 2015, ENOsubmitted a certification that a determination to permanentlycease power operations wasmade on December 29, 2014, pursuant to 10 CFR 50.82(a)(1)(i). ENO hassubmitted written certification tothe NRC, in accordance with 10 CFR 50.82(a)(1) that meets therequirements of 10 CFR50.4(b)(9) certifying that fuel has been permanently removed fromthe reactor vessel and placed inthe Spent Fuel Pool. Upon docketing of these certifications, the 10 CFR Part 50 license forhas been revised to indicatethe permanently shutdownand defueled condition.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE15 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeVY no longer authorizesoperation of the reactor oremplacement or retention of fuel into the reactor vessel, asspecified in 10 CFR 50.82(a)(2).With irradiated fuel being storedin the Spent Fuel Pool and the ISFSI, the reactor, reactorcoolant system and secondarysystem are no longer in operation and have no functionrelated to the storage of theirradiated fuel. Therefore, the postulated accidents involving failure or malfunction of thereactor and reactor coolantsystem or secondary system are no longer applicable.Section 4.2 - 2nd Paragraph The nearest house is 1,300 feetfrom the Reactor Building and is one of several west of the site.

The Vernon Elementary School(approximate enrollment of 250pupils) is about 1,500 feet from the Reactor Building. Thenearest hospital, BrattleboroMemorial, is approximately five (5) miles north-northwest fromthe site. The nearest dairy farmis approximately 1/2-mile northwest of the site. Additional dairy farms are located within a5-mile radius of the plant. Thelargest sports facility in theThe nearest house is 1,300 feetfrom the Reactor Building and is one of several west of the site.

The Vernon Elementary School(approximate enrollment of 250pupils) is about 1,500 feet from the Reactor Building. Thenearest hospital, BrattleboroMemorial, is approximately five (5) miles north-northwest fromthe site. The nearest dairy farmis approximately 1/2-mile northwest of the site. Additional dairy farms are located within a5-mile radius of the plant. Anursing home is located 2 milesEditorial. The HinsdaleRaceway no longer operates and reference is removed from theEmergency Plan.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE16 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changevicinity is the Hinsdale Raceway,located approximately three (3)miles from the site. For racing events, the average attendanceis approximately 4,000. Anursing home is located 2 miles south of the plant. These areas have been noted since they haverequired special planningconsideration by offsite authorities in the event of aradiological emergency atVermont Yankee.south of the plant. These areashave been noted since they haverequired special planning consideration by offsiteauthorities in the event of aradiological emergency at Vermont Yankee.Section 5.1 - 1st ParagraphNotification of Unusual EventEvents are in process or haveoccurred which indicate apotential degradation of the level of safety of the plant or indicatea security threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite response ormonitoring are expected unlessfurther degradation of safety systems occurs.Notification of Unusual EventEvents are in progress or haveoccurred which indicate apotential degradation of the level of safety of the plant or indicate asecurity threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite response ormonitoring are expected unlessfurther degradation of safety systems occurs.Editorial revision to reflectdefinition in NEI 99-01, Rev.5Section 5.1 - 2nd Paragraph Notification of Unusual Eventconditions do not cause serious damage to the plant and may not require a change in operationalstatus. The purpose of theNotification of Unusual Event declaration is to: 1) ensure thatthe first step in any responselater found to be necessary hasNotification of Unusual Eventconditions do not cause serious damage to the plant. The purpose of the Notification ofUnusual Event declaration is to:1) ensure that the first step in any response later found to benecessary has been carried out;2) bring the operating staff to aVY will no longer be anoperating nuclear power plant. A change in operational status is not aconsideration due to thepermanently shutdown and defueled plant condition.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE17 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changebeen carried out; 2) bring theoperating staff to a state ofreadiness; and 3) ensure that appropriate offsite notificationshave been made in the eventthat additional support is required.state of readiness; and 3) ensurethat appropriate offsitenotifications have been made in the event that additional supportis required.Section 5.2 - 1st ParagraphAlertEvents are in process or haveoccurred which involve an actual or potential substantialdegradation of the level of safetyof the plant or a security event that involves probable life threatening risk to site personnelor damage to site equipmentbecause of HOSTILE ACTION.

Any releases are expected to belimited to small fractions of theEPA Protective Action Guideline exposure levels.AlertEvents are in progress or haveoccurred which involve an actual or potential substantialdegradation of the level of safetyof the plant or a security event that involves probable life threatening risk to site personnelor damage to site equipmentbecause of HOSTILE ACTION.

Any releases are expected to belimited to small fractions of theEPA Protective Action Guideline exposure levels.Editorial revision to reflectdefinition in NEI 99-01, Rev.5Section 5.3 - 1st ParagraphSite Area EmergencyEvents are in process or haveoccurred which involve an actual or likely major failures of plantfunctions needed for protectionof the public or HOSTILE ACTION that results in intentional damage or maliciousacts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) thatprevent effective access toSite Area EmergencyEvents are in progress or haveoccurred which involve an actual or likely major failures of plantfunctions needed for protectionof the public or HOSTILE ACTION that results in intentional damage or maliciousacts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) thatprevent effective access toEditorial revision to reflectdefinition in NEI 99-01, Rev.5 ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE18 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeequipment needed for theprotection of the public. Anyreleases are not expected to result in exposure levels whichexceed EPA Protective ActionGuideline exposure levels beyond the site boundary.equipment needed for theprotection of the public. Anyreleases are not expected to result in exposure levels whichexceed EPA Protective ActionGuideline exposure levels beyond the site boundary.Section 5.4 - 1st ParagraphGeneral EmergencyEvents are in process or haveoccurred which involve actual or imminent substantial coredegradation or melting withpotential for loss of containment integrity or HOSTILE ACTION that results in an actual loss ofphysical control of the facility.Releases can be reasonably expected to exceed EPAProtective Action Guidelineexposure levels offsite for more than the immediate site area.General EmergencyEvents are in progress or haveoccurred which involve actual or imminent substantial coredegradation or melting withpotential for loss of containment integrity or HOSTILE ACTION that results in an actual loss ofphysical control of the facility.Releases can be reasonably expected to exceed EPAProtective Action Guidelineexposure levels offsite for more than the immediate site area.Editorial revision to reflectdefinition in NEI 99-01, Rev.5Figure 6.2See "After" ColumnReplaced "Comm. Room" with"Main TSC Area"Editorial revision toaccurately depict TSClayout.Figure 6.3See "After" Column Deleted "Radiation ProtectionOffices" Changed "OSCCommunication Center" to "OSC Manager and Briefing Room" Deleted "Chemistry Offices" Changed "Briefing Room" to"Rad Protection"Editorial revision toaccurately depict OSClayout.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE19 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Change Changed "Rad Prot" to "NCORoom" Changed "AO Room" to"NCO Room"Figure 6.4See "After" Column Deleted "HVAC Room" Added "NRC Room" Changed "Chemistry &Sample Anal. Lab" to "Chemistry and Sample Analysis 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"Editorial revision toaccurately depict EOF/RClayout.Section 7.3The Utility Microwave and RadioSystems are located in the Control Room. The Utility Microwave is a line-of-sightdedicated system used to notifysystem load dispatchers of emergency conditions at theplant. The telephone hasThe Utility Microwave and RadioSystems are located in the Control Room. In the event that communications fail with theNRC due to loss of thecommercial telephone system, load dispatchers are advised thatVermont Yankee will use theVY will no longer be anoperating nuclear power plant. There will no longer be a need to notify systemload dispatchers ofemergency conditions at the plant because the potentialto disrupt the power grid will ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE20 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changebuttons marked for each loaddispatcher. By pushing one ofthe buttons on the telephone, it rings automatically at theselected location. In the eventthat communications fail with the NRC due to loss of the commercial telephone system,the load dispatchers are advisedthat Vermont Yankee will use the Utility 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-hour manning capability at theirorganizations. The systems aretested once a week with both organizations.Utility Microwave System toprovide updates of plantconditions to NRC Region I.no longer exist.Section 7.107.10Emergency Response DataSystemThe Emergency Response DataSystem (ERDS) is a direct real-time electronic transmissionof the following types ofparameters to the NRC to assist them in monitoring the status ofan emergency: Core and coolant systemdata, Containment buildingDeletedVY will no longer be anoperating nuclear powerplant.Section VI.1 of Appendix E to 10 CFR Part50 indicates that ERDS isnot applicable to nuclear power facilities that are shutdown. Based on thepermanently defueled status, this system is no longer necessary to transmitsafety system parameterdata to the NRC.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE21 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changedata, Radioactivity releasedata, and Site meteorological data.Vermont Yankee maintains acontinuous ERDS connectionwith the NRC Operations Center.NRC Memorandum from theDirector, Division ofPreparedness and Response (NSIR) toRegions (Division of ReactorProjects) clarifies the requirements for maintenance and use ofERDS by licensees whohave submitted certification of permanent cessation ofoperations pursuant toSection 50.82, "Termination of Licenses," in Part 50, "Domestic Licensing ofProduction and UtilizationFacilities," of Title 10 of the Code of FederalRegulations, (10 CFR Part50)." This memorandum is publicly available in ADAMS(ML14099A520).Table 7.1:State Police (VT, NH, MA)from CRState Police (VT, NH, MA)from EOFState EOCs (VT, NH, MA)State EOCs (VT, NH, MA)from EOF1, 21, 21, 2, 91, 2, 9, 101, 2, 111, 2, 111, 2, 9, 111, 2, 9, 10, 11 Add InForm to Table Key as #11InForm added to theEmergency Plan in Rev. 54.Section 8.1 - 2nd Paragraph During normal operations, theminimum staff on duty at theThe minimum staff on duty at theplant during all shifts consists ofVY will no longer be anoperating nuclear power ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE22 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason 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. The responsibility for determining thestatus of the plant in anemergency is assigned to the Shift Manager or, in his absence from the Control Room, to theControl Room Supervisor whohas the authority and responsibility to immediatelyinitiate any emergency actions,including emergency classification and notification.Additional personnel areavailable on an on-call basis to respond to plant emergencies.

Corrective action and repair, asoutlined in Table 8.4, isperformed by Operations staff on-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 indicated in Figure 8.1. The responsibility for 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 to immediately initiate any emergency actions, includingemergency classification andnotification. Additional personnel are available on an on-call basisto respond to plant emergencies.Corrective action and repair, as outlined in Table 8.4, isperformed by Operations staffon-shift until supplemented by additional 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 and removal of fuel from thereactor vessel, Operationson-shift personnel will consist of one (1) Shift Manager (SM), one (1)Certified Fuel Handler(CFH) and three (3) Non-Certified Operators (NCOs).Title changes for the CRS toCFH and the AO and CRO to NCO were dependent upon NRC approval ofproposed changes to theVY Technical Specifications (BVY 13-096) that replacedreferences to licensed andnon-licensed operators with references to CFHs andNCOs. This TechnicalSpecification change was approved by the NRC by letter dated December 22,2014 (ML14217A072).

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE23 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeThese staffing levels havebeen evaluated in the VYanalysis of proposed post-shutdown on-shift staffing inconjunction with thepostulated accidents that will be applicable in the permanently defueledcondition.Section 8.2 - 2nd Paragraph Elements of the emergencyresponse plan are activatedsubsequent to an emergencydeclaration by the Shift Manager; designated company personnel are notified and will report todesignated locations. Theemergency response action of the personnel already presentare performed on a priority basisdepending on the emergency conditions and the immediate need which those conditionsdictate as determined by theonshift operations crew. The specific priorities facing theemergency response forces inthe various locations cannot be pre-established. They would bespecific to the nature of theemergency and variable with time as it proceeds.Elements of the emergencyresponse plan are activatedsubsequent to an emergencydeclaration by the Shift Manager; designated company personnel are notified and will report todesignated locations. Theemergency response action of the personnel already presentare performed on a priority basisdepending on the emergency conditions and the immediate need which those conditionsdictate as determined by the on-shift operations crew. The specific priorities facing theemergency response forces inthe various locations cannot be pre-established. They would bespecific to the nature of theemergency and variable with time as it proceeds.Editorial change from"onshift" to "on-shift"Section 8.2 - 5th Paragraph In emergency situations, theShift Manager, Emergency PlantManager, or OSC Manager canIn emergency situations, theShift Manager, Emergency PlantManager, or OSC Manager canVY will no longer be anoperating nuclear powerplant and emplacement or ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE24 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeauthorize actions, withoutfollowing the complete workorder process, if these actions prevent the following: Loss of importantequipment, Personnel injury, or Plant trip.authorize actions, withoutfollowing the complete workorder process, if these actions prevent the following: Loss of importantequipment, or Personnel injury.retention of fuel into thereactor vessel will no longerbe authorized. Therefore a plant trip will no longer beapplicable.Section 8.2.2 - 1stParagraph, Item 55. Develop guidance for plantshift operations concerning plant protection of the reactor core;5. Develop guidance for plantshift operations concerning plant protection;VY will no longer be anoperating nuclear power plant and emplacement orretention of fuel into thereactor vessel will no longer be authorized. Therefore, the need for the EmergencyPlant Manager'sresponsibilities to include protection of the reactorcore is no longer applicable.Section 8.2.2 - 2ndParagraphA qualified manager assumesthe role of Emergency Plant Manager under all emergencyconditions. To assist theEmergency Plant Manager, the TSC is staffed byrepresentatives from thefollowing departments as depicted in Figure 8.3: Operations MaintenanceA qualified manager assumesthe role of Emergency Plant Manager under all emergencyconditions. To assist theEmergency Plant Manager, the TSC is staffed by representativesfrom the following departmentsas depicted in Figure 8.3: Operations MaintenanceVY will no longer be anoperating nuclear power plant and emplacement orretention of fuel into thereactor vessel will no longer be authorized. Therefore,the need to maintain aReactor Engineer in the TSC is no longer applicable.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE25 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Change Reactor Engineering Engineering Chemistry (in the OSC) Radiation Protection Security (stationed at theoff site command post) Engineering Chemistry Radiation Protection Security (stationed at theoff site command post)Section 8.2.4EOF ManagerDeleted entire sectionThe EOF Manager positionwill not exist in the Permanently Defueled ERO.

Duties and responsibilitieswill be transferred toremaining positions within the EOF.Section 8.2.10During implementation of SevereAccident Management (SAM),

the senior licensed individual in the TSC will assume the role ofDecision Maker as defined in theSAM Guideline.During implementation of SevereAccident Management (SAM),

the Operations Coordinator in the TSC will assume the role ofDecision Maker as defined inplant procedures.EPOP-TSC-3542 states thatthe Operations Coordinator in the TSC assumes the duty of SAM DecisionMaker.Table 8.3, Page 2 of 3Each State Health representativeat the EOF/RC will requestmonitoring updates from the EOF Manager.Each State Health representativeat the EOF/RC will requestmonitoring updates from the Lead Offsite Liaison.The EOF Manager positionwill not exist in thePermanently Defueled ERO.

Duties and responsibilities will be transferred toremaining positions withinthe EOF.Table 8.3, Page 3 of 3The Public Information Liaison atthe EOF/RC relays accidentstatus reports to the Joint Information Center.The Technical Advisor at theEOF/RC relays accident statusreports to the Joint Information Center.The position of PublicInformation Liaison will notexist in the Permanently Defueled Emergency Response Organization ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE26 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Change(ERO). Duties andresponsibilities will betransferred to the Technical Advisor position.Table 8.4 - Page 1 of 2,Functional Area - PlantOperations & Assessment of Operational AspectsVY will no longer be anoperating nuclear powerplant. The following on-shift positions will be eliminated: STA Two (2) Control RoomOperators Three (3) AuxiliaryOperators Chemistry TechnicianFollowing permanentcessation of operations andremoval of fuel from thereactor vessel, Operations on-shift personnel willconsist of the SM, one (1)CFH and three (3) NCOs.

Title changes for the CRS to CFH and AO and CRO toNCO were dependent uponNRC approval of proposed changes to the VYTechnical Specifications(BVY 13-096) that replaced references to licensed and non-licensed operators withreferences to CFHs andNCOs. This Technical Specification change was ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE27 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason 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 in conjunction with thepostulated accidents thatwill be applicable in the permanently defueledcondition.STA oversight and technicalknowledge in this functional area will be transferred tothe Shift Manager and/orthe CFH. This transfer of duties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing inconjunction with thepostulated accidents previously submitted to the NRC.Table 8.4 - Page 1 of 2; Functional Area -

Notification/Communication;Major Tasks - NotifyLicensee, State, local and federal personnel & maintain communicationVY will no longer be anoperating nuclear power plant. The STA position willbe eliminated.Following permanentcessation of operations, the Chemistry TechnicianPosition will not be ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE28 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeresponsible for performingnotification/communicationstasks.STA assignments in thisfunctional area will betransferred to a CRS/CFH.

This transfer of duties has been evaluated in the VYanalysis of proposed post-shutdown on-shift staffing in conjunction with thepostulated accidents thatwill be applicable in the permanently defueled condition.Title change for the CRS toCFH was dependent upon NRC approval of proposedchanges to the VYTechnical Specifications (BVY 13-096) that replacedreferences to licensed andnon-licensed operators with references to CFHs and NCOs. This TechnicalSpecification change wasapproved by the NRC by letter dated December 22,2014 (ML14217A072).Table 8.4 - Page 1 of 2;Functional Area -

Radiological AccidentAssessment and Support ofOperational AccidentVY will no longer be anoperating nuclear power plant. The STA and on-shiftChemistry Tech positions ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE29 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeAssessment; Major Tasks -Offsite Dose Assessmentwill be eliminated.STA assignments in thisfunctional area will be transferred to the ShiftManager and/or the ControlRoom Supervisor. This transfer of duties and removal of the on-shiftChemistry Tech positionhave been evaluated in the VY analysis of proposedpost-shutdown on-shiftstaffing in conjunction with the postulated accidents that will be applicable in thepermanently defueledcondition.Title changes for the CRS toCFH was dependent uponNRC approval of proposed changes to the VYTechnical Specifications(BVY 13-096) that replaced references to licensed and non-licensed operators withreferences to CFHs andNCOs. This Technical Specification change wasapproved by the NRC byletter dated December 22, 2014 (ML14217A072).Table 8.4 - Page 1 of 2;Functional Area -Radiological AccidentThis change does notrepresent a change to thenumber of on-shift RP ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE30 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeAssessment and Support ofOperational AccidentAssessment; Major Tasks -

Onsite (out of plant)Technicians. The number ofon-shift RP Techniciansremains one (1). The change is intended to clarifyVY's RP Technician dutiesduring an emergency, consistent with Table B-1 of NUREG-0654.Table B-1 of NUREG-0654does not identify an on-shift position responsible for"onsite (out of plant)"surveys. During the initial stages of an emergency, the on-shift RP Technician willbe assigned to the mostcritical tasks during the emergency response. VYmaintains the capability toaugment on-shift staff with field monitoring teams toperform this task within 30minutes of notification of an emergency declaration.Table 8.4 - Page 1 of 2;Functional Area -Radiological Accident Assessment and Support ofOperational AccidentAssessment; Major Tasks -

Chemistry/RadiochemistryVY will no longer be anoperating nuclear powerplant. The on-shift Chemistry Tech position willbe eliminated.Removal of the on-shiftChemistry Tech position has been evaluated in theVY analysis of proposedpost-shutdown on-shift ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE31 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changestaffing in conjunction withthe postulated accidentsthat will be applicable in the permanently defueledcondition.Table 8.4 - Page 1 of 2;Functional Area - Plant System Engineering; MajorTasks - Shift TechnicalAdvisor and Core Thermal HydraulicsVY will no longer be anoperating nuclear power plant. The STA position willbe eliminated.STA oversight and technicalknowledge in this functionalarea will be transferred tothe Shift Manager and/or the CRS/CFH. This transfer of duties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing in conjunctionwith the postulatedaccidents that will be applicable in the permanently defueledcondition.Additionally, the need tomaintain a Reactor Engineerin the TSC is no longerapplicable.Table 8.4 - Page 1 of 2; Functional Area - Repair &Corrective Actions; MajorTasks - Mechanical MaintenanceThe Defueled Organizationcontains three (3) NCOs on-shift. This on-shiftcomplement has been evaluated in the VY analysisof proposed post-shutdown ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE32 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeon-shift staffing inconjunction with thepostulated accidents that will be applicable in thepermanently defueledcondition.Title changes for the AO toNCO were dependent uponNRC approval of proposedchanges to the VY Technical Specifications(BVY 13-096) that replacedreferences to licensed and non-licensed operators with references to CFHs andNCOs. This TechnicalSpecification change was approved by the NRC byletter dated December 22,2014 (ML14217A072).Table 8.4 - Page 1 of 2; Functional Area - Repair &Corrective Actions; MajorTasks - Rad Waste OperatorThe CRO position iseliminated in the post-shutdown condition. TheDefueled Organization consists of three (3) NCOson-shift. This on-shiftcomplement has been evaluated in the VY analysisof proposed post-shutdownon-shift staffing in conjunction with the postulated accidents thatwill be applicable in thepermanently defueled ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE33 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changecondition.Title changes for the AOand CRO to NCO were dependent upon NRCapproval of proposedchanges to the VY Technical Specifications (BVY 13-096) that replacedreferences to licensed andnon-licensed operators with references to CFHs andNCOs. This TechnicalSpecification change was approved by the NRC by letter dated December 22,2014 (ML14217A072).Table 8.4 - Page 1 of 2;Functional Area - Repair &Corrective Actions; MajorTasks - Electrical Maintenance/Instrumentation

& Control TechnicianThe Defueled Organizationconsists of three (3) NCOson-shift. This on-shiftcomplement has been evaluated in the VY analysis of proposed post-shutdownon-shift staffing inconjunction with the postulated accidents thatwill be applicable in thepermanently defueled condition.Title change for the AO toNCO was dependent upon NRC approval of proposed changes to the VYTechnical Specifications(BVY 13-096) that replaced ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE34 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changereferences to licensed andnon-licensed operators withreferences to CFHs and NCOs. This TechnicalSpecification change wasapproved by the NRC by letter dated December 22, 2014 (ML14217A072).Table 8.4 - Page 2 of 2; Functional Area - Protective Actions (In Plant); MajorTasks - RadiationProtection, access control, HP, coverage for repair, corrective actions, search &rescue, first aid & firefighting,personnel monitoring, dosimetryThe Defueled Organizationconsists of three (3) NCOs on-shift. This on-shiftcomplement has beenevaluated in the VY analysis of proposed post-shutdown on-shift staffing inconjunction with thepostulated accidents that will be applicable in thepermanently defueledcondition.Title change for the AO toNCO was dependent uponNRC approval of proposedchanges to the VY Technical Specifications(BVY 13-096) that replacedreferences to licensed and non-licensed operators withreferences to CFHs andNCOs. This Technical Specification change was approved by the NRC byletter dated December 22,2014 (ML14217A072).

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE35 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeTable 8.4, Note ****May be performed byengineering aide to ShiftManager (STA for ENVY)DeletedVY will no longer be anoperating nuclear powerplant. The STA position will be eliminated. STAoversight and technicalknowledge will be transferred to the Shift Manager and/or theCRS/CFH. This transfer ofduties has been evaluated in the VY analysis ofproposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will beapplicable in thepermanently defueled condition.Table 8.4, Note 1AP 0894 specifies minimum shiftstaffing requirements. FB requires 5 persons per TRM and the Vermont Yankee NuclearPower Station On-Shift StaffingAnalysis. The staffing analysis is maintained as a controlleddocument and is effective 30days after OSRC approval. STA and Chemistry Tech must beavailable within 10 minutes tothe Control Room. VY letter to NRC dated 4/14/1981 (FVY 81-

65) establishing position. VYletter to NRC 6/22/1982 (FVY82-75) Supplement -NUREG 0737 Item III.A.1.2 on training ofAP 0894 specifies minimum shiftstaffing requirements. FB requires 5 persons per TRM and the Vermont Yankee NuclearPower Station Analysis ofProposed Post-Shutdown On-Shift Staffing. The staffinganalysis was evaluated to reflectVY's permanently shutdown and defueled conditions, includingthe on-shift staff composition andrevised accident analyses.The Defueled on-shiftstaffing has been evaluated in the VY analysis of proposed post-shutdown on-shift staffing in conjunctionwith the postulated accidents that will beapplicable in thepermanently defueled condition.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE36 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeon-shift staff to support VYposition for staffing. VY letter toNRC 4/14/1981 (FVY 81-65) TMI Action Plan Item III.A.1.2, goalfor augmentation of staff. VYletter to NRC 6/15/82 (FVY 82-

70) Results of Augmentation drills 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 are trained to self-monitor in an emergency.All NCOs use digital dosimeterswith features for dose rate andtotal dose monitoring. NCOs are trained to self-monitor in an emergency.Title changes for the AOsand CROs to NCO weredependent upon NRC approval of proposed changes to the VYTechnical Specifications(BVY 13-096) that replaced references to licensed andnon-licensed operators withreferences to CFHs and NCOs. This Technical Specification change wasapproved by the NRC byletter dated December 22, 2014 (ML14217A072).Table 8.4, Note 3ENVY has designated pagerholders who staff positions required to meet minimum staffing to activate TSC, OSCand EOF (see E Plan Figures8.3 through 8.5). There are a minimum of 4 persons perposition (4 teams who rotateduty). However, all persons onENVY has designated EROmembers who staff positions required to meet minimum staffing to activate the TSC, OSCand EOF. The minimum staffpositions required to activate the TSC and EOF are shown in EPlan Figures 8.3 and 8.5. TheOSC Manager is the onlyThe Defueled Organizationwill consist of fewer than 4 teams rotating ERO duty.Additional changes to thisnote are editorial to removereferences to pagers and pager holders.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE37 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeteams are expected to respond.In addition, all other EROpersonnel not on pagers are notified by the emergency call-innotification system and areexpected to respond.position required to activate andstaff the OSC. All EROpersonnel are expected to respond when notified by theemergency call-in notificationsystem.Table 8.4, Note 4The on-shift Shift Manager,CRS, STA, and Chem Techhave the capability to do initialdose assessment and PAR. The TSC 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 EOF radiation assessment staffrelieves them of this function.VY will no longer be anoperating nuclear powerplant. The STA and on-shiftChemistry Technician positions will be eliminated.Title changes for the CRS toCFH were dependent upon NRC approval of proposed changes to the VYTechnical Specifications(BVY 13-096) that replaced references to licensed andnon-licensed operators withreferences to CFHs and NCOs. This Technical Specification change wasapproved by the NRC byletter dated December 22, 2014 (ML14217A072).CFHs will supervise fuelhandling operations in the permanently defueledcondition. The CRS and SMwill be qualified as CFHs.

However, the SM requires additional qualificationbeyond the CFH training.Therefore, any reference to ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE38 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changethe CFH position throughoutthis Plan is considered to beequivalent to the CRS position. NCOs will performduties typically associatedwith those performed by Auxiliary Operators and Control Room Operators,such as manipulation andmonitoring of plant equipment.Figure 8.1Normal On-Shift EmergencyOrganizationReplaced figure with "DefueledOn-Shift Emergency Organization" figure.Deleted the following positions: Shift Technical Advisor Chem Tech Control Room OperatorsReplaced "Control RoomSupervisor" with "Certified FuelHandler"Replaced "Auxiliary Operators"with "Non-Certified Operator"VY will no longer be anoperating nuclear power plant. The following on-shift positions will be eliminated: STA Two (2) Control RoomOperators Three (3) AuxiliaryOperators Chemistry TechnicianFollowing permanentcessation of operations andremoval of fuel from thereactor vessel, Operations on-shift personnel willconsist of the SM, one (1)CFH and three (3) NCOs.

Title changes for the CRS to CFH and AO and CRO toNCO were dependent uponNRC approval of proposed changes to the VY ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE39 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeTechnical Specifications(BVY 13-096) that replacedreferences to licensed and non-licensed operators withreferences to CFHs andNCOs. This Technical Specification change was approved by the NRC byletter dated December 22,2014 (ML14217A072).These staffing levels havebeen evaluated in the VYanalysis of proposed post-shutdown on-shift staffing in conjunction with thepostulated accidents thatwill be applicable in the permanently defueledcondition.STA oversight and technicalknowledge in this functionalarea will be transferred tothe Shift Manager and/or the CRS/CFH. This transfer of duties has been evaluatedin the VY analysis ofproposed post-shutdown on-shift staffing in conjunctionwith the postulatedaccidents previously submitted to the NRC.Figure 8.2VY Emergency ManagementOrganizationReplaced figure with "VYDefueled EmergencyThe positions of EOFManager and TSC Managerwill not exist in the ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE40 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeManagement Organization"Deleted the following positions: EOF Manager TSC ManagerPermanently Defueled ERO.Duties and responsibilitieswill be transferred to remaining positions withineach Emergency ResponseFacility.Figure 8.3Technical Support CenterEmergency OrganizationReplaced figure with "DefueledTechnical Support CenterEmergency Organization"Deleted the following positions: TSC Manager TSC Communicator Mechanical Engineer Reactor Engineer Electrical /I&C Engineers IT SpecialistThe TSC positions identifiedfor deletion will not exist inthe Permanently DefueledERO. Duties and responsibilities will betransferred to remainingpositions within the TSC.Figure 8.4Operations Support CenterEmergency OrganizationDeleted figureERO Staffing changes resultin one remaining OSCposition (OSC Manager) - A figure is no longernecessary to describe theOSC organization.Figure 8.5Emergency Operations FacilityOrganizationReplaced figure with "DefueledEmergency Operations FacilityOrganization"Deleted the following positions: EOF Manager EOF Communicator Public Information Liaison EOF Log Keeper IT SpecialistThe EOF positions identifiedfor deletion will not exist inthe Permanently DefueledERO. Duties and responsibilities will betransferred to remainingpositions within the EOF.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE41 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeFigure 8.7Joint Information CenterOrganizationReplaced figure with "DefueledJoint Information CenterOrganization"Deleted the following positions: Information Coordinator Technical Assistant Credentialing Press Release Writer Logistics Coordinator Inquiry ResponseCoordinator Media Monitoring JIC Log Keeper Inquiry RespondersThe JIC positions identifiedfor deletion will not exist inthe Permanently Defueled ERO. Duties andresponsibilities will betransferred to remaining positions within the JIC.Section 9.2.1 - 2ndParagraph3. The Shift Technical Advisorreports to the Control Room and provides technical support as necessary;DeletedVY will no longer be anoperating nuclear power plant. The STA position will be eliminated.STA assignments in thisfunctional area will be transferred to the CFHposition. This transfer ofduties has been evaluated in the VY analysis ofproposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will beapplicable in thepermanently defueled condition.Section 9.2.25. The EOF Manager5. The Emergency DirectorThe EOF Manager position ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE42 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeestablishes operations in theEOF/RC;establishes operations in theEOF/RC;will not exist in thePermanently Defueled ERO.Duties and responsibilities will be transferred toremaining positions withinthe EOF.Section 9.2.4 - 2ndParagraph1. The Emergency Director mayrequest that the EOFManager mobilize otherpersonnel in support of Vermont Yankee throughactivation of the CorporateEmergency Center.1. The Emergency Director mayrequest that other personnelbe mobilized in support ofVermont Yankee through activation of the CorporateEmergency Center.The EOF Manager positionwill not exist in thePermanently Defueled ERO.Duties and responsibilities will be transferred toremaining positions withinthe EOF.Section 9.3 - 3rd Paragraph De-escalation from a Notificationof Unusual Event to a recoveryphase requires satisfying thefollowing criteria:1. Criticality controls are ineffect;2. The core is being adequatelycooled;3. The fission product releasehas been controlled;4. Control has been establishedover containment pressureand temperature;5. An adequate heat transferpath to an ultimate heat sink has been established;6. Reactor coolant systempressure is under control;De-escalation from a Notificationof Unusual Event to a recoveryphase requires satisfying thefollowing criteria:1. Criticality controls are ineffect;2. The fission product releasehas been controlled;3. An adequate heat transferpath to an ultimate heat sinkhas been established;4. Notification of Unusual Eventconditions have beenreviewed, are under control, and are not expected to deteriorate further.VY will no longer be anoperating nuclear powerplant and emplacement orretention of fuel into the reactor vessel will no longerbe authorized. Therefore,the need for adequate core cooling, control over containment pressure andtemperature and control ofreactor coolant system pressure is not necessary.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE43 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeand/or7. Notification of Unusual Eventconditions have been reviewed, are under control,and are not expected todeteriorate further.Table 9.1, Technical Support Center; Alert or Site AreaEmergency or GeneralEmergency ColumnEmergency Plant ManagerTSC ManagerMaintenance Coordinator(Electrical/Mechanical/I&C)Radiological CoordinatorReactor EngineerEngineering Coordinator(Project,System, Design)Operations CoordinatorEngineering Support GroupEmergency Plant ManagerMaintenance Coordinator(Electrical/Mechanical/I&C)Radiological Coordinator Engineering Coordinator(Project,System, Design)Operations CoordinatorThe TSC positions identifiedfor deletion will not exist inthe Permanently DefueledERO. Duties and responsibilities will betransferred to remainingpositions within the TSC.Table 9.1, Operations Support Center; Alert or SiteArea Emergency or GeneralEmergencyOSC ManagerRadiation Protection StaffChemistry StaffSpare Licensed Operators Spare Auxiliary Operators Control Instrument SpecialistsPlant MechanicsOSC ManagerRadiation Protection StaffChemistry StaffSpare AOs/CROs/NCOs Control Instrument Specialists Plant MechanicsVY will no longer be anoperating nuclear powerplant. Use of the term"licensed" is no longer appropriate.The OSC positions identifiedfor deletion will not exist inthe Permanently Defueled ERO. Duties andresponsibilities will betransferred to remaining positions within the OSC.Table 9.1, EmergencyEmergency DirectorEmergency DirectorThe EOF positions identified ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE44 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeOperations Facility/RecoveryCenter; Alert or Site AreaEmergency or General Emergency ColumnOffsite CommunicatorTechnical AdvisorEOF Manager Administration and LogisticsCoordinatorRadiological AssessmentCoordinatorPersonnel & Equipment Monitor*Site/Offsite Monitoring TeamsPublic Information LiaisonOffsite CommunicatorTechnical AdvisorAdministration and LogisticsCoordinatorRadiological AssessmentCoordinator*Site/Offsite Monitoring Teamsfor deletion will not exist inthe Permanently DefueledERO. Duties and responsibilities will betransferred to remainingpositions within the EOF.Table 9.1, Joint InformationCenter; Alert or Site AreaEmergency or General EmergencyCompany SpokespersonVY Public Information StaffNuclear Public InformationRepresentativesJoint Information Center StaffCompany SpokespersonThe JIC positions identifiedfor deletion will not exist inthe Permanently Defueled ERO. Duties and responsibilities will betransferred to remainingpositions within the JIC.Section 10.1.110.1.1 Initial Offsite Radiological DoseProjection CapabilityVermont Yankee has developeda method to quickly determinethe projected offsite radiological conditions at various distancesdownwind of the plant site.During the initial stages of an emergency, the Shift Manager ordesignated individual isresponsible to perform the initial evaluation of offsite radiological conditions. The initial evaluationDeletedThe Unified Rascal Interface(URI) will become theprimary site specific dose assessment software for Vermont Yankee. Thiscomputer program replacesthe existing ODPS and METPAC dose assessmentsoftware.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE45 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeof offsite radiological conditionsis accomplished by utilizing theOffsite Dose Projection System (ODPS).The ODPS utilizes a straight lineGaussian plume dispersion model programmed on the plant process computer. The programallows the user the option toselect one of two release pathways (elevated or ground)and to utilize site-specificradiological and meteorological information to estimate the Total Effective Dose Equivalent andadult thyroid Committed DoseEquivalent (elevated release only) 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/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorologicaland radiological accident conditions.The system assumes a Gaussian, variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Stationsite. Both continuous and intermittentreleases for either ground or stack release points can be evaluated. The effects of release height, building wakeVermont Yankee utilizes a plumetracking/dose projection system, which is capable of providing near real time offsite dose estimated for actual meteorological and radiologicalaccident conditions. The systemassumes a variable trajectory, plume segment transport model designed to handle the site-specific atmospheric dispersion characteristics associated with the Vermont Yankee Nuclear Power Station site. Both continuousand intermittent releases for eitherground or stack release points can be evaluated. The effects of release height, building wake entrainment,The Unified Rascal Interface(URI) will become the primary site specific doseassessment software forVermont Yankee. This computer program replacesthe existing ODPS andMETPAC dose assessment software. This section isrevised to describe URI.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE46 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeentrainment, momentum plume rise,precipitation and terrain height can beassessed in the evaluation. Plumetrajectories are based on onsite meteorological tower information and topography of the Connecticut River Valley.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 a personal computer. The program is designed to graphically display the calculated plume characteristics on a 10-mile Vermont Yankee EPZ site mapwhile providing transcripts of alldispersion and dose calculations.nally, the OffsiteDose Nomogram can beused to determine an activity releaserate (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 by using Figure 10.1 with the followingadditional information:after reactor shutdown;plant stack high range monitor response;plant stack flow rate at the time of theaccident; and speed.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 tower information and topography of the Connecticut River Valley.The model combines complex plumetransport algorithms with dose assessment algorithms. The model isprogrammed on a personal computer.The program is designed to graphically display the calculated plume characteristics on a 10-mile Vermont Yankee EPZ site map while providing transcripts of all dispersion and dose calculations.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE47 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeFigure10.1 is discussed in Appendix C.Section 10.2 - 1st Paragraph In the event a GeneralEmergency has been declared,Vermont Yankee immediately recommends protective actionsto state authorities based onplant conditions which include the status of core and containment conditions. At aminimum, the Shift Manager orEmergency Director, who is in charge of the emergencyresponse activities, recommendsthat the general public be advised to seek shelter for thetowns of Hinsdale, NewHampshire and Vernon, Vermont; and the towns located five miles downwind in theaffected sectors.In the event a GeneralEmergency has been declared,Vermont Yankee immediately recommends protective actionsto state authorities based onplant conditions. At a minimum, the Shift Manager or Emergency Director, who is in charge of theemergency response activities,recommends that the general public be advised to seek shelterfor the towns of Hinsdale, NewHampshire and Vernon, Vermont; and the towns locatedfive miles downwind in theaffected sectors.VY will no longer be anoperating nuclear powerplant and emplacement or retention of fuel into thereactor vessel will no longerbe authorized. Therefore, the need to communicate the status of the core andcontainment conditions isnot necessary.Section 10.2 - 2nd ParagraphIf plant conditions indicate asevere reactor accident existsinvolving actual or projectedsubstantial core damage, Vermont Yankee recommends to the appropriate state officialsevacuation of the towns ofHinsdale, New Hampshire and Vernon, Vermont; and all townslocated five miles downwind inthe affected sectors.If plant conditions indicate asevere accident exists, VermontYankee recommends to theappropriate state officials evacuation of the towns of Hinsdale, New Hampshire andVernon, Vermont; and all townslocated five miles downwind in the affected sectors.VY will no longer be anoperating nuclear powerplant and emplacement orretention of fuel into the reactor vessel will no longer be authorized. Therefore, anaccident involving thereactor the potential for actual or projectedsubstantial core damage nolonger exists.Section 10.3 - 2nd ParagraphTable 10.2 specifies theguidelines on emergency doselimits for personnel providingTable 10.2 specifies theguidelines on emergency doselimits for personnel providingVY will no longer be anoperating nuclear powerplant. The on-shift ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE48 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeemergency response dutieswhich is consistent with theEnvironmental Protection Agency Emergency WorkerDose Limit Guides (EPA400-R-92-001). The Shift Manager initially has the responsibility to authorizeemergency dose commitmentsuntil relieved by the Emergency Plant Manager. Thisauthorization is coordinated withthe assistance of the Radiological Coordinator or Shift Chemistry and RadiationProtection Technicians asneeded. Exposure to individuals providing emergency functionswill be consistent with the limitsspecified in Table 10.2 with every attempt made to keepexposures ALARA.emergency response dutieswhich is consistent with theEnvironmental Protection Agency Emergency WorkerDose Limit Guides (EPA400-R-92-001). The Shift Manager initially has the responsibility to authorizeemergency dose commitmentsuntil relieved by the Emergency Plant Manager. Thisauthorization is coordinated withthe assistance of the Radiological Coordinator and Radiation Protection Techniciansas needed. Exposure toindividuals providing emergency functions will be consistent withthe limits specified in Table 10.2with every attempt made to keep exposures ALARA.Chemistry Technicianpositions will be eliminated.Section 10.5.1Medical Response Teammembers are trained in accordance with stationprocedures.Medical response is provided byon-shift Fire Brigade members trained in basic first-aid andCardiopulmonary resuscitation(CPR).The Medical ResponseTeam is being eliminated.

Medical response will beprovided by Fire Brigademembers available on site on a 24-hour per day basis.Section 10.6A range of protective actions toprotect onsite personnel duringhostile action is provided to ensure the continued ability tosafely shut down the reactor andperform the functions of theA range of protective actions toprotect onsite personnel duringhostile action is provided to ensure the continued ability tomaintain equipment important tothe safe storage of spent fuelRevised to reflect importantequipment duringpermanently shutdown and defueled plant condition.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE49 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for Changeemergency plan.and perform the functions of theemergency plan.Figure 10.1Figure 10.1 Vermont YankeeEmergency Dose Rate NomogramDeleted FigureVY will no longer be anoperating nuclear power plant. Figure 10.1 is nolonger applicable because itis based on the isotopic mix for a LOCA.Section 11.3 - 4th Paragraph The Public Information Liaisonand required staff report to the EOF/RC for coordinating the accident information between theplant and the Joint InformationCenter.The Technical Advisor andrequired staff report to the EOF/RC for coordinating the accident information between theplant and the Joint InformationCenter.The Technical Advisor willassume this duty in the permanently defueled condition.Section 11.3 - 6th Paragraph Normally, a prerecordedmessage provides, on a dailybasis, routine operating information, changes in plant operation, and other items ofinterest.Normally, a prerecordedmessage provides, on a dailybasis, routine plant information, changes in plant conditions, and other items of interest.VY will no longer be anoperating nuclear powerplant.Section 12.1.4 - Medical DrillsTo evaluate the training of thefacility's medical response teamand offsite medical response(ambulance and hospital), a medical drill is conducted annually with a simulatedcontaminated injured individual.To evaluate the training of thefacility's medical response andoffsite medical response(ambulance and hospital), a medical drill is conducted annually with a simulatedcontaminated injured individual.The Medical ResponseTeam is being eliminated.Medical response will beprovided by Fire Brigade members available on site on a 24-hour per day basis.Appendix B(A more detailed listing ofemergency equipment isprovided in OP 3506,"Emergency Equipment Readiness Check")(A more detailed listing ofemergency equipment isprovided in OP-EQUIP-3506,"Emergency Equipment Readiness Check")Editorial revision toprocedure number.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE50 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeAppendix CAppendix C Initial Offsite DoseRate EstimationAppendix deleted in its entiretyVY will no longer be anoperating nuclear powerplant. Appendix C is no longer applicable because itis based on the isotopic mixfor a Loss of Coolant Accident (LOCA).Appendix G - Section IOP-3507OP-3508OP-3510 OP-3513OP-3547OP-3548 AP-3712EPOP-EREC-3507EPOP-MED-3508EPOP-OSMT-3510 EPOP-RAD-3513EPOP-SEC-3547EPOP-TERM-3548 EPAP-TRNG-3712Editorial revision toprocedure numbers.Appendix G - Section INot ApplicableAdd:V-EN-FAP-EP-009, Use of KI forthe Emergency Response OrganizationV-EN-FAP-EP-010, SevereWeather ResponseV-EN-FAP-EP-012, SevereWeather RecoveryV-EN-EP-202, EquipmentImportant to Emergency PreparednessV-EN-EP-301, EmergencyPlanning Assessment of Offsite Emergency Response CapabilitySee below.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE51 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeFollowing a Natural DisasterV-EN-EP-305, EmergencyPlanning 10CFR50.54(q) Review ProgramV-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 INot ApplicableAdd:EPOP-AFA-10083 - AlternativeFacility ActivationEPOP-URI-10095 - Offsite DoseAssessment using the UnifiedRascal InterfaceEPOP-AFA-10083 wasdeveloped and added to theEmergency Plan forcompliance with 10 CFR Part 50, Appendix E SectionIV.E.8.d.EPOP-URI-10095 wasdeveloped and added to theEmergency Plan to addressthe change to URI.

ATTACHMENT9.1PROCESSAPPLICABILITYDETERMINATIONFORMPAGE52 OF52EN-LI-100 REV. 16Emergency Plan SectionBefore (Rev. 54)AfterReason for ChangeAppendix G - CorporateSupport ProceduresCorporate Support ProceduresDeletedEN-EP-311 will be deleted.VY will no longer be anoperating nuclear power plant.Section VI.1 ofAppendix E to 10 CFR Part50 indicates that ERDS is not applicable to nuclear power facilities that are shutdown. Based on thepermanently defueled status, this system is nolonger necessary to transmitsafety system parameter data to the NRC.The applicable informationfrom the remainingprocedures will be relocated to a VY-specific procedureand added to the EPIP list(see above) and the Corporate Support Sectionof Appendix G will bedeleted.EN-EP-309 and EN-EP-606will be deleted as neitherprocedure is applicable toVY. These procedures should not have beenincluded in the VYEmergency Plan and removal is an editorialchange.