ML14231A019

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

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

Text

SEntergyEntergy Nuclear Operations, Inc.Vermont Yankee320 Governor Hunt RdVernon, VT 05354Tel 802 257 7711Christopher J. WamserSite Vice PresidentBVY 14-054August 14, 2014ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555SUBJECT: Proposed Changes to the Vermont Yankee Emergency Plan -Supplement 2 (TACNo. MF3668)Vermont Yankee Nuclear Power StationDocket No. 50-271License No. DPR-28REFERENCES: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "ProposedChanges to the Vermont Yankee Emergency Plan," BVY 14-018,dated March 24, 2014 (TAC No. MF3668) (ADAMS Accession No.ML14085A257)2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "ProposedChanges to the Vermont Yankee Emergency Plan -Supplement 1(TAC No. MF3668)," BVY 14-034, dated May 21, 2014 (ADAMSAccession No. ML14149A048)3. Letter, USNRC to Entergy Nuclear Operations, Inc. "Vermont YankeeNuclear Power Station -Request For Additional InformationRegarding License Amendment Request For Emergency PlanChange (TAC No. MF3668)," NVY 14-055, dated July 1, 2014(ADAMS Accession No. ML14163A590)Dear Sir or Madam:By letter dated March 24, 2014 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) proposedan amendment to Renewed Facility Operating License (OL) DPR-28 for Vermont Yankee NuclearPower Station (VY). The proposed amendment would revise the site emergency plan (SEP) forthe permanently defueled condition. The proposed SEP changes would revise the on-shift staffingand Emergency Response Organization (ERO) staffing levels.Reference 2 provided a response to an NRC Request for Additional Information (RAI) regardingthe proposed SEP changes. In Reference 3, the NRC provided VY with an additional RAIregarding the proposed SEP changes. Attachment 1 of this letter provides the responses to theRAI. Attachment 2 contains revised SEP pages and Attachment 3 contains an updated summary ofthe proposed SEP changes.The conclusions of the no significant hazards consideration and the environmental considerationscontained in Reference 1 are not affected by, and remain applicable to, this supplement.

BVY 14-054 / page 2 of 2This letter contains no new regulatory commitments.If you have any questions on this transmittal, please contact Mr. Philip Couture at 802-451-3193.I declare under penalty of perjury that the foregoing is true and correct.Executed on August 14, 2014.Sincerely,CJW/plcAttachments: 1. Response to Request for Additional Information2. Revised SEP Pages3. Updated Tabular Summary of Proposed Changes to SEPcc: Mr. William M. DeanRegion 1 AdministratorU.S. Nuclear Regulatory Commission2100 Renaissance Blvd, Suite 100King of Prussia, PA 19406-2713Mr. James S. Kim, Project ManagerDivision of Operating Reactor LicensingOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionMail Stop 08C2AWashington, DC 20555USNRC Resident InspectorVermont Yankee Nuclear Power Station320 Governor Hunt RoadVernon, VT 05354Mr. Christopher Recchia, CommissionerVT Department of Public Service112 State Street, Drawer 20Montpelier, VT 05620-2601 BVY 14-054Docket 50-271Attachment 1Vermont Yankee Nuclear Power StationResponse to Request for Additional Information BVY 14-054 / Attachment 1 / Page 1 of 12REQUEST FOR ADDITIONAL INFORMATIONREGARDING AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGEENTERGY NUCLEAR OPERATIONS. INC.VERMONT YANKEE NUCLEAR POWER STATIONDOCKET NO. 50-271RAI-VY-01Attachment 1 (on Page 2 of 23) states:NCOs [non-certified operators] will perform duties typically associated with thoseperformed by AOs [auxiliary operators] and CROs [control room operators], such asmanipulation and monitoring of plant equipment. NCOs will also be assigned tomonitor indications and communications in the Control Room.Please specify what is the level of training provided to the NCOs to perform the duties of theAOs/CROs with respect to operation and monitoring of plant equipment, mitigativestrategies, and emergency plan training?ResponseThe Non-Certified Operator (NCO) Training Program is currently under development in accordancewith 10 CFR 50.120. The NCO position combines the post-shutdown duties of the licensed ReactorOperator (RO) and the non-licensed Auxiliary Operator (AO). The specific training requirements ofthe NCO position are currently being drafted by the Vermont Yankee (VY) Training Departmentand have not yet been reviewed and approved by Operations management. The draft trainingrequirements include classroom training in theory and systems topics, administrative procedures,off-normal and transient procedures/mitigation strategies and refuel platform operations. Thetraining program is designed with an emphasis on systems/processes important to maintainingSpent Fuel Pool (SFP) cooling and monitoring and controlling SFP parameters, such as SFP waterlevel and temperature. Consequently, the NCOs will be trained on pertinent Control Roomindications and controls that will be monitored and operated to maintain SFP cooling and SFPwater level, in addition to plant radiological conditions.The drafted NCO training program will also include training on applicable aspects of the VY SiteEmergency Plan (SEP) related to NCO duties.Although non-licensed AOs are currently trained to function as the Control Room Communicator,VY makes no specific commitment to train NCOs in this role because it is anticipated that the twoCertified Fuel Handlers (CFHs) that will be located in the Control Room during a declaredemergency will maintain responsibility for Emergency Plan communications.Personnel assigned to fill the NCO positions during the post-shutdown period, prior toimplementation of the Permanently Defueled Emergency Plan (PDEP), are a mixture of licensedROs and non-licensed AOs. The majority of the required training for the NCO position will alreadyhave been completed by the licensed ROs because they have previously been trained andqualified as both Reactor and Auxiliary Operators to support power operations. The current AOs BVY 14-054 / Attachment 1 / Page 2 of 12have been trained and qualified as non-licensed operators only. Therefore it is expected they willrequire additional training to address skill and knowledge gaps related to Control Room operations.Once the specific training requirements for the NCO position have been identified using asystematic approach to training, as required by 10 CFR 50.120, a formal gap analysis will becompleted for all operators identified to fill the NCO position. Individualized training plans will bedeveloped and completed to address the identified knowledge and skills gaps for the selectedNCO candidates. This will include training the currently qualified AOs on Control Room indications,controls and procedures.RAI-VY-02Attachment 1 (on Page 6 of 23) states:The OSC [operations support center] Manager is the only position required toactivate and staff the OSC.In addition, Section 6.1.2 of the Site Emergency Plan (SEP) states:It is staffed with sufficient in-plant personnel required to effect protective andcorrective actions in support of the emergency situation.Please explain how the OSC can be staffed with sufficient in-plant personnel required toeffect protective and corrective actions in support of the emergency situation if the OSCManager is the only position required to activate and staff the OSC?ResponseThe primary functions of the OSC will remain dispatching of, and accounting for, Repair andCorrective Action Teams and dispatching of Site Boundary and Offsite Monitoring Teams. TheOSC Manager is responsible for ensuring adequate staffing of the OSC to support the emergency;working with the Emergency Plant Manager to set priorities for the OSC; and directing the activitiesof the OSC to support emergency response. If, at any time, the OSC Manager determinesadditional manpower is necessary to accomplish the mission of the OSC, the OSC Manager willcontact the Administration and Logistics Coordinator in the EOF to arrange for augmentation byadditional personnel to support the emergency response functions of the OSC.The spectrum of credible accidents and operational events, and the quantity and complexity ofactivities required for the safe storage of spent nuclear fuel is reduced as compared to anoperating plant. The primary events of concern in the immediate post-shutdown and defueledcondition will be a fuel handling accident and a loss of SFP cooling and/or water inventory. Duringfuel handling activities there will be extra personnel on site that will, were a fuel handling accidentto occur, be able to respond to the event. Events involving a loss of SFP cooling and/or waterinventory can be addressed by implementation of SFP inventory makeup strategies required under10 CFR 50.54(hh)(2). These strategies will also continue to be required as a license condition.OSC staff is not relied upon to implement SFP inventory makeup.

BVY 14-054 / Attachment 1 / Page 3 of 12RAI-VY-03Attachment 1 / page 7 of 23 provides:Table 1 shows the TSC [technical support center] Reactor Engineer has a yes forminimum staff position.In addition, Attachment 1 (on Page 2 of 23) provides that the TSC Reactor Engineer is aposition that ENO proposes to eliminate. These statements are in conflict. Please clarifywhether the TSC Reactor Engineer is being retained as minimum staffing or providejustification for removal as a minimum staffing position.ResponseThese statements are reconciled as follows. The intent of Table 1 is to compare the current EROpositions against the proposed post-shutdown ERO positions and identify whether each position iscurrently a minimum staff position. The TSC Reactor Engineer is a position that is being eliminatedin the post-shutdown ERO. Table 1 in Attachment 1 of Reference 2 identifies the Reactor Engineeras a current minimum staff position and the position is not included as a proposed position in thepost-shutdown ERO upon implementation of the changes identified in Reference 2.Attachment 5 of emergency plan procedure EPOP-TSC-3542 outlines the duties of the TSCReactor Engineer position. Specifically, Section 2.2 of Attachment 5 identifies the duties as follows:* Assist the Shift Manager, Emergency Plant Manager, TSC Manager and EngineeringCoordinator, as necessary." Assist operations personnel in calculating and tracking core reactivity.* Assist the Engineering Coordinator in clarifying core parameter information.* Perform a core damage assessment if an ATWS [anticipated transient without scram]condition or fuel failure exists.* Work with other TSC Engineers to provide support to the Control Room to mitigate theeffects of the event and return the plant to a safe condition.* Assist in Severe Accident Management Guideline implementation, when requested." Provide recommendations to plant operators.* Assist in developing emergency procedures, if needed.Attachment 5 of Reference 2 identifies three primary duties for the Reactor Engineer, including:determining and providing an estimate of core damage, assisting in the implementation of SevereAccident Management Guidelines and providing core parameter information results to the TSCManager. In a permanently shutdown and defueled condition, responsibilities associated with areactor core no longer need to be maintained. Any other duties described in implementingprocedures that are unrelated to core assessment, such as assisting the Emergency PlantManager, TSC Manager and Engineering Coordinator; assisting with implementation of SevereAccident Management Guidelines; providing recommendations to plant operators; and assisting indeveloping emergency procedures are either no longer necessary in a permanently defueledcondition or will be performed by other members of the post-shutdown ERO.

BVY 14-054 / Attachment 1 / Page 4 of 12RAI-VY-04Attachment 1 (on Page 8 of 23) states:ERO duties have been reviewed and duties for eliminated positions will betransferred appropriately.Please describe by what process has this been validated and documented for theemergency operations facility (EOF) and Joint Information Center (JIC)?ResponseEach current ERO position is identified and the associated duties are captured in the ERO TaskAnalysis provided in Attachment 5 of Reference 2. The duties of the EOF and JIC positions thatare being eliminated were reviewed against NUREG-0654, and VY procedures EN-EP-801,"Emergency Response Organization," EN-TQ-1 10, "Emergency Response Organization Training,"and EN-TQ-1 10-01, "Fleet Emergency Plan Training Course Summary." Each of the eliminatedpositions was analyzed to identify the key duties associated with the position and the duties werethen evaluated against the planning standards in NUREG-0654.The Table provided in Attachment 5 of Reference 2 contains columns with headings "ImplementingActions" and 'Task Assigned To?" These columns provide the details for disposition of each task.This analysis was peer-checked by VY Emergency Planning. Procedures and training materialsdepicting the changes presented in Attachment 5 of Reference 2 will be developed. Some of theduties are identified as being eliminated because they become unnecessary following permanentcessation of operations and permanent removal of fuel from the reactor vessel. Other duties areidentified as eliminated because the duties are performed by other positions of the ERO in the EOFor JIC and will continue to be performed by these positions in the post-shutdown ERO.The proposed changes to the VY SEP, including the minimal changes made to the ERO to developthe post-shutdown ERO, have been evaluated for impacts on the EOF and the JIC and for theability of offsite response organizations to implement their FEMA-approved RadiologicalEmergency Preparedness (REP) Plans. This analysis was provided to the NRC in Reference 3. Asdescribed in Reference 3, potential impacts on the ability of State and local response organizationsto effectively implement their FEMA-approved REPs do not exist because no tasks that requireinterfacing with State and local response organizations are proposed for elimination. VY hasappropriately addressed elimination of ERO positions that interface with offsite representatives bytransferring the necessary tasks to remaining post-shutdown ERO positions.To validate the results of the analysis described in Reference 3, drills will be developed andconducted in the 4th quarter of 2014, prior to the requested approval date of Reference 2. Thedrills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessaryfunctions of each emergency response facility and will utilize the post-shutdown procedurescurrently being developed depicting the revised assignment of duties. The drills will be used to trainand qualify post-shutdown ERO members, evaluate and validate the ability to accomplish thestated mission of each emergency response facility, and ensure that the planning standardfunctions are preserved with no degradation in time sensitive activities or in the ability tocommunicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the SEP, BVY 14-054 / Attachment 1 / Page 5 of 12site commitments and applicable regulation. Drill dates will be provided to the NRC in advance andthe NRC staff will be provided the opportunity to observe the drills. Additionally, supportinginformation regarding the drills will be provided to the NRC staff, if requested.RAI-VY-05Attachment 1 (on Page 10 of 23) states:When the on-shift Chemistry Technician position is eliminated, the on-shift RadiationProtection Technician will be able to perform sampling and analysis, so as to notdelay information potentially needed by the SM [Shift Manager] to determine if anemergency declaration is required.Please describe what specific training is provided to the on-shift Radiation ProtectionTechnician to be qualified to perform these samples and analyses functions?ResponseThe incumbent Radiation Protection (RP) Technicians currently receive specific training moduleswhich prepare them to perform sampling and analysis at various locations throughout the plant.Similar to Chemistry Technicians, incumbent RP Technicians have been trained on how to analyzethese samples using a Multi-Channel Analyzer (MCA). These analyses are performed using anapproved station procedure and a computerized MCA menu which guides the technician to selectthe correct counting geometry for various sample types.There are no new skills or basic knowledge requirements involved in training incumbent RPTechnicians to perform liquid sampling and analysis to support an emergency declaration.Currently, a Training Evaluation and Action Request (TEAR VTY-2014-163) is tracking thecompletion of the gap analysis between current RP Technician training requirements and any newspecific knowledge requirements associated with emergency plan sampling and analysis. Suchspecific knowledge requirements would include how to obtain specific liquid samples. This TEARwill also track the completion of any required gap training for the incumbent RP Technicians whohave been selected to fill SAFSTOR positions.The initial training requirements for any new SAFSTOR RP Technician will include all trainingmodules to ensure they are equipped with the required skills and knowledge to perform therequired liquid sampling and analysis. These training modules will be specifically identified in theSAFSTOR training program description for the RP Technician position. This document is currentlybeing developed in accordance with the requirements of 10 CFR 50.120.RAI-VY-06Attachment 1 (on Page 14 of 23) states:The TSC Reactor Engineer position can be eliminated without increasing the risk tothe public health and safety because the major task of evaluating core/thermalhydraulics is not necessary in a permanently shutdown and defueled condition.

BVY 14-054 / Attachment 1 / Page 6 of 12Please explain whether the expertise of the TSC Reactor Engineer position would be neededto provide any technical evaluation support for an event in the spent fuel pool (e.g., a draindown event that may require an evaluation of the condition of the fuel to determine anypossible recommendations for offsite agencies to consider).ResponseElimination of the TSC Reactor Engineer position will have no effect on emergency response in apermanently defueled condition because the position does not assess the condition of fuel in theSFP during an emergency. The current TSC Reactor Engineer position satisfies the technicalsupport Core/Thermal Hydraulics position included in Table B-1 of NUREG-0654. TSC ReactorEngineers have expertise in the area of core damage assessment and core parameter monitoring.Table B-1 does not identify an on-shift position responsible for evaluation of fuel in the SFP duringan emergency. TSC Reactor Engineers are not trained to provide this type of technical evaluation.Instead, offsite technical assistance would need to be obtained to perform this analysis.RAI-VY-07Attachment 1, Section 5.2.6 (on Page 17 of 23) states:The function of these additional resources is to provide RP [radiation protection]oversight of the on-shift complement of personnel and augmented personnel whoare expected to respond to emergency events for damage repair, corrective actions,search and rescue, first aid, firefighting and personnel monitoring. They can also beexpected to provide for access control and the issuance of dosimetry. Analysis ofthe proposed change for each of these tasks is discussed below. The fire brigade willcontinue to perform the tasks of search and rescue, first aid and firefighting in thepermanently defueled condition.In addition, Attachment 3, Table 8.4 (on Page 2 of 2) provides:Protective Actions (In Plant) Shift AO/CRO/NCO (2**)2 on shift Note 2. AllAOs/CROs/NCOs use digital dosimeters with features for dose rate and total dosemonitoring. AOs/CROs/NCOs are trained to self-monitor in an emergency.The information in Note 2 is not consistent with that provided in Attachment 1, as citedabove. There is a difference between self-monitoring and "providing RP oversight" asdescribed in Section 5.2.6.* Please clarify how RP oversight is provided for search and rescue, and firefighting.Based on the proposed on-shift staffing, it appears that they may be part of the firebrigade, and therefore, it would be a collateral duty.* Please clarify how the fire brigade members that may be primarily engaged infirefighting efforts or search and rescue missions are provided RP coverage.

BVY 14-054 / Attachment 1 / Page 7 of 12Please describe what training is provided that qualifies these two operationspositions to perform RP oversight. Please refer to NRC Health Physics Position(HPPOS) 238, "Health Physics Position of Task Qualification of HP Technicians," indeveloping your response.ResponseThe portion of Table 8.4 referenced in the RAI was revised in Reference 2 only to indicate the titlechange for the Control Room Operator and Auxiliary Operator to Non-Certified Operator and doesnot represent any changes in radiation protection oversight from the currently assignedresponsibilities, Section 8.1 and Table 8.4 of the SEP identify one (1) on-shift RP Technician.The two operators identified in the portion of Table 8.4 referenced in the RAI are members of thefire brigade. They do not provide RP oversight during firefighting and search and rescueoperations. Because the on-shift RP Technician provides RP oversight during search and rescueor firefighting, there are no collateral duties for the operators. The operators are trained to self-monitor in circumstances where it is safe to do so. Access control and personnel monitoring aredescribed in section 5.2.6.1 of Reference 2.RAI-VY-08Attachment 1, Section 5.2.6.1 (on Page 17 of 23) states:Worker access control is now automated because RP work processes have beencomputerized.Please clarify whether there are active emergency Radiation Work Permits for use at alltimes in the event of emergency or are they required to be activated after an emergencyclassification.ResponseVY does not have Radiation Work Permits that must be activated after an emergency classification.Instead, existing, active Radiation Work Permits are available at all times, including during anemergency.An annual Radiation Work Permit dedicated for emergency plan response will be written andavailable on the first day of each year which will pre-authorize access for emergency responsepersonnel in accordance with emergency plan implementing procedures. Site personnel will benotified of the Radiation Work Permit via site wide email and shift turnover as part of the annualreminder to review new Radiation Work Permits. No additional training will be necessary as use ofRadiation Work Permits is addressed in radiation worker training.

BVY 14-054 / Attachment 1 / Page 8 of 12RAI-VY-09Attachment 1, Section 5.2.6.1 (on Page 17 of 23) states:No RP involvement is necessary for this contamination monitoring activity becauseworkers are trained to perform this task without supervision or oversight.Please clarify whether these workers are trained to remove tools and/or equipment from theRadiologically Controlled Area or do they require RP support.ResponseThe contamination monitoring activities described in the RAI are specific to personnel monitoringand monitoring of personal items and radiation workers are trained in these tasks. However,workers are not trained to remove tools and/or equipment from the RCA. Removing tools and/orequipment from the RCA would require monitoring by a qualified RP Technician as is currentlyrequired by station procedures.RAI-VY-10Attachment 3, Table 8.4 (on Page 1 of 2) states:Onsite (out of plant) Shift RP Tech (1) on shiftIn plant surveys Shift RP Tech (1) on shiftBased on the staff's review, it appears that there would be two RP technicians on-shift sincethere is no designation that these major tasks may be collateral duties. Please confirm thatthis conclusion is correct in regards to the number of on-shift RP technicians.ResponseVY's current on-shift staffing complement includes one (1) RP Technician. The post-shutdown on-shift staffing changes proposed in Reference 2 do not include any changes to the number of on-shift RP Technicians. The current On-Shift Staffing Analysis has concluded that the current on-shiftstaff is able to cope with the spectrum of analyzed events until augmenting ERO staff arrives.Likewise, the analysis of the proposed post-shutdown on-shift staffing includes one (1) on-shift RPTechnician. The analysis, developed to evaluate the ability of the proposed post-shutdownminimum on-shift staff to implement all emergency tasks, concludes that the proposed on-shift staffis able to cope with the spectrum of analyzed events in a permanently shutdown and defueledcondition until augmenting ERO staff arrives.Table B-1 of NUREG-0654 identifies the minimum staffing requirements for nuclear power plantemergencies. Table B-1 does not identify an on-shift position responsible for "onsite (out of plant)"surveys. During the initial stages of an emergency, the on-shift RP Technician will be assigned tothe most critical tasks during the emergency response. For consistency with Table B-1 of NUREG-0654, ENO proposes to delete the reference to the RP Technician "on-site (out of plant)" entry inSEP Table 8.4. VY maintains the capability to augment on-shift staff with field monitoring teams to BVY 14-054 / Attachment 1 / Page 9 of 12perform this task within 30 minutes of notification of an emergency declaration. Attachment 2 ofthis response provides the revised pages of the SEP with the proposed changes shown instrikethrough and underline format resulting from the change to Table 8.4 and the proposedchange to the SEP is included in the Tabular Summary of Proposed Changes included asAttachment 3 of this response.RAI-MY-1 1Attachment 3, Section 9.2.2.5 (on Page 83 of 125) states:The EOF Manager establishes operations in the EOF/RC ...However, Table 1 in Attachment 1 (on Page 7 of 23) indicates that this position is beingeliminated. This position is also referenced in Attachment 3, Section 9.2.4 and numeroussections in the SEP that are not indicated in Attachment 3. Please clarify whether the EOFManager position is being retained or eliminated, and provided appropriate supportingjustification.ResponseThe EOF Manager position is being eliminated. Attachment 2 of this response provides the revisedpages of the SEP with the proposed changes shown in strikethrough and underline format resultingfrom the elimination of the EOF Manager position. The Tabular Summary of Proposed Changes toSite Emergency Plan, included as Attachment 2 to Reference 2, has been updated and is includedas Attachment 3 of this response.When operational, the EOF/RC assumes overall responsibility for the implementation of theemergency plan and serves as the near-site facility established to coordinate the activities of VYemergency response personnel; evaluate offsite accident conditions; and maintain coordinationand communications with offsite response authorities. According to emergency planning procedureEPOP-EOF-3546, the EOF Manager is currently responsible for overseeing operations of theEOF/RC and assisting the Emergency Director in performance of key duties. Section 8.2.4 of theSEP currently describes the primary responsibilities of the EOF Manager as: 1) establish the EOFwhen required; 2) assess EOF habitability via the Radiological Assessment Coordinator; and 3)prepare the EOF for the arrival of offsite authorities and other support personnel. The duties of theEOF Manager are administrative in nature. The position has no role in accident assessment ormitigation activities and the position is not required to declare the facility operational.The current ERO staffing required by the SEP and implementing procedures is intended to addressthe risks to public health and safety inherent in an operating reactor. As noted in Reference 2, EROduties have been reviewed and duties for eliminated positions will be transferred to remaining EROpositions. Attachment 5 of Reference 2 provides the analysis of duties performed by the ERO,including the EOF Manager. Some of these duties are identified as being eliminated because theyare already performed by other members of the ERO in the EOF and transfer of the responsibilityis not necessary to ensure performance of the duty. The duties of the EOF Manager that are notcurrently performed redundantly by other ERO positions will not be eliminated, but will betransferred to the Emergency Director, Administration and Logistics Coordinator, EOF Technical BVY 14-054 / Attachment 1 / Page 10 of 12Advisor, Lead Off-Site Liaison or the Offsite Communicator in the EOF. Transfer of these duties isidentified in Attachment 5 of Reference 2.If additional resources are needed to support emergency response, the Emergency Director willassist or direct the Administration and Logistics Coordinator in obtaining additional resources.RAI-VY-1 2Attachment 4,Section V.2 (on Page 12) states:VY has 30 and 60 minute emergency responders when augmented while the ERO isoffsite. This analysis was conducted assuming a 90 minute response of theaugmented ERO to allow the use of this analysis for a possible future extension inERO augmentation times. There were no specific emergency response tasksassigned to the augmented ERO prior to the 90 minute response.The staff is reviewing this application for proposed changes to on-shift staffing and 30/60minute augmented responders, and not for the acceptability of a 90 minute augmentedresponse. Please clarify the extent of changes being requested under ENO's licenseamendment.ResponseENO is not requesting NRC review of any changes to the current 30/60 minute augmentedresponse times. The statement included in Attachment 4, referenced, above, was provided forinformational purposes only and documents an assumption used in the analysis.RAI-VY-1 3The staff's previous request for additional information, RAI-VY-01, based on our initialacceptability review, requested the following:Please identify whether the proposed changes to the [Vermont Yankee NuclearPower Station] VY SEP were evaluated for their impact with the State and localresponse organizations ability to effectively implement their [Federal EmergencyManagement Agency) FEMA-approved [radiological emergency preparedness]REP plans, specifically in regards to licensee interface and coordination withState and local response organizations? If so, please provide evaluation performedand documentation regarding discussions with affected State and local responseorganizations used in making this determination.In ENO's response dated May 21, 2014, it is not apparent to the staff that the State and localresponse organizations performed this review of their plan. ENO's response appears toindicate that ENO performed these evaluations. Please clarify whether the affected Stateand local response organizations independently performed the review of their affectedplans and concur with the results provided in the ENO's response dated May 21, 2014, or ifnot, please identify the areas of issues and how these issues are resolved.

BVY 14-054 / Attachment 1 / Page 11 of 12ResponseAn email was sent on June 17, 2014 to the appropriate emergency management officials from thestates of Vermont, New Hampshire and Massachusetts requesting that they confirm that anyneeded changes to the State emergency response plans or procedures associated with thepositions being eliminating from the ERO after the shutdown of VY have been identified and thatthe SEP changes still provide for adequate coordination and interface with the State emergencyresponse organizations. By July 1, 2014, representatives from each State emergency managementagency had replied that reviews of their radiological emergency response plans had beencompleted and that no additional changes to any of the plans were identified during this review.RAI-VY-14The staff's previous RAI (RAI-VY-02), based on our initial acceptability review, requested thefollowing:If potential impacts to OROs exist, have the proposed changes to the VY SEP beenreviewed and agreed upon by the affected OROs to ensure they can continue to meetthe requirements of their current FEMA-approved emergency plans? Please providedocumentation that the affected OROs have reviewed and concurred on theproposed changes.FEMA/NRC MOU [Memorandum of Understanding] establishes a "framework ofcooperation" regarding the maintenance of REP programs to ensure continued reasonableassurance. Under the MOU, FEMA is responsible for determining the adequacy of offsiteREP plans and preparedness and providing its findings to the NRC "to make radiologicalhealth and safety decisions in the issuance of licenses and the continued operation oflicensed plants." The NRC will be providing the proposed changes to the facilities that haveinterface with the State and local response organizations to FEMA for their review.ENO's response dated May 21, 2014, apparently did not address this request. Pleaseprovide documentation that the affected State and local response organizations are inagreement with the proposed changes, or if not, please identify the areas of issues and howthese issues are resolved.ResponseAs discussed in the response to RAI-VY-01 3, reviews of the proposed changes for impact on theirradiological emergency response plans by representatives from the emergency managementagencies from Vermont, New Hampshire and Massachusetts was documented by email exchange.These emails have been provided to the NRC staff.

BVY 14-054 / Attachment 1 / Page 12 of 12References1. Letter, Entergy Nuclear Operations, Inc. to USNRC "Request for Approval of CertifiedFuel Handler Training Program," BVY 13-095, dated October 31, 2013 (TAC No.MF2998) (ADAMS Accession No. ML13325B015)2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the VermontYankee Emergency Plan," BVY 14-018, dated March 24, 2014 (TAC No. MF3668)(ADAMS Accession No. ML14085A257)3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Proposed Changes to the VermontYankee Emergency Plan -Supplement 1 (TAC No. MF3668)," BVY 14-034, dated May21, 2014 (ADAMS Accession No. ML14149A048)

BVY 14-054Docket 50-271Attachment 2Vermont Yankee Nuclear Power StationRevised SEP Pages 8.2.4. EOF-ManagefDeletedThe EOF Marnager is a dsignated staff member of Vermont Yankee .anagementspecifically trained to be responrSble for the Eme=rgeRny Plan with respect tooperation of the EOFiRCI. The EOF. Managers' primary respRnsibilities are to:-1 .Establish the Emergency Operations Facility when required;2. Assess E~mergency Operations Facility habitability via the RadiologicalAssessment Coodinator;3. Prepare the Emergency Operations Facility for the arrival of offsite authoritiesand otheFr SUPPrt persRnnel.Emergency Operations Facility Manager at an AleF- oF higher emergency classification.The EFQF Manager is responsible for repeoting to the E=mergency Director.Emergency PlanRevision -54PENDINGPage 53 of 125Entergy Vermont Yankee TABLE 8.3 (Continued)(Page 2 of 3)A SUMMARY OF OFFSITE COORDINATIONEMERGENCY PLAN FUNCTIONPLANT RESPONSIBILITYSTATE RESPONSIBILITYLOCAL RESPONSIBILITYProtective Action DecisionMaking (continued)Each State Health representativewould call or report to the plant for thefollow-up protective actionrecommendation issued by theEmergency Director.Each State Health representative willreview all factors and issue a finalrecommendation to the Directors ofState Emergency managementAgencies, who, in turn, will initiateresponse actions to implement thisrecommendation.A coordination between the States willdecide the time to implement theproposed actions, including activatingthe public alert and instructionalmethods (e.g., siren activation/NOAmessage, etc.)Each State Health representative atthe EOF/RC will request monitoringupdates from the FOQFManagef LeadOffsite Liaison.In the State of Vermont, the Director ofthe Division of Occupational &Radiological Health & Safety willcommand this function at the StateEOC.Coordination of Radiological DataThe Radiological AssessmentCoordinator is responsible forcompiling offsite monitoring resultsand for ensuring an effectivedeployment of monitoring personnelas well as coordinating informationtransfer.Local communities rely onState capability for radiologicalevaluation.Emergency PlanRevision 54PENDINGPage 62 of 125Entergy Vermont Yankee Table 8.4(Page 1 of 2)MINIMUM STAFFING REQUIREMENTS FOR THE ENVY EROFUNCTIONAL MAJOR TASKS ENVY POSITION TITLE1 RESPONSEAREA TIMEPlant Operations & Shift Manager (1) On ShiftAssessment of CRS/Certified Fuel Handler (CFH).... (1) On ShiftOperational Aspects On Q-ShiftAG-(6+AO/CRO/NCO*... (3) On ShiftSTA444 On ShiftEmergency Direction Shift Manager (1**) On Shift& Control(EmergencyCoordinator)***Notification / Notify Licensee, State .T.AO CRS/CFH On ShiftCommunication ..*. local and federal STA-Offsite Comm/ENS Comm/-eh-,T-eh4 30 min.personnel & maintain (1) 3 60 min.communication S-TAlOffsite Comm/ENS CommiGhe#rnTec-(2) 3Radiological Emergency Operations EOF Emergency Director (1) 60 min.Accident Facility (EOF) Director Shift MgrjCRS!CFH.ST.A.he. Tch On ShiftAssessment and Offsite Dose assessment RP Staff (1)4 30 min.Support ofOperational Accident Off site surveys Field monitoring teams (2) 30 min.Assessment Field monitoring teams (2) 60 min.Onsite (out of plant) ShiftRPe GoW,-, ( i-Sh)Field monitoring teams (1) 3 30 min.Field monitoring teams (1) 60 min.In plant surveys Shift RP Tech (1) On ShiftRP staff (1) 30 min.RP staff (1) 60 min.Chemistry/ Shif Chem. Tech (1) On Shi#6ORadiochemistry Chem staff (1) min._ _ _60mmf4Plant System Shift Technical Advisor Positions not needed in a Permanently GPS1qftEngineering Core/Thermal hydraulics Defueled ConditionS-TA)+44 .Electrical TSC Manager / TSC Engineering staff (1) 60 min.Mechanical TSC Manager / TSC Engineering staff (1) 60 min.Repair & Corrective Mechanical Maintenance Sb4-AOShift AO/CRO/NCO-1(I** On ShiftActions Mechanical Maintenance Maintenance (1) 60 min.Rad Waste operator AOICRO(!AO/CROINCO 60 min.Electrical Maintenance / Shit-AOShift AO/CRO/NCO-(I**) On ShiftInstrumentation & Control Maintenance (1) 30 min.Technician Maintenance (1) 60 min.Instrumentation & Control Maintenance (1) 30 min.TechnicianEmergency PlanRevision 54PENDINGPage 64 of 125Entergy Vermont Yankee 44-.12. The public information representative is notified and handles publicinformation associated with the event; and44-.13. The Shift Manager terminates the Notification of Unusual Event status andcloses out the event with a verbal summary to offsite authorities or escalatesto higher level emergency classification.9.2.1.1. Unusual Event (Terminated) ResponseIf a condition that warrants a Notification of Unusual Event declaration has occurred, andwas immediately rectified such that the condition no longer existed by the time ofdeclaration, this Notification of Unusual Event classification is referred to as an UnusualEvent (Terminated).The event or condition did not affect personnel onsite or the public offsite, Or result inradioactive releases requiring offsite monitoring.The response to this declaration of an Unusual Event (Terminated) is not ascomprehensive as that for a Notification of Unusual Event. All the same notifications for aNotification of Unusual Event are made, and emergency response personnel reporting tothe plant are based on specific requests of the SM.9.2.2. Alert ResponseAn Alert requires actions to: 1) assure that sufficient emergency response personnel aremobilized to respond to the accident conditions at the site; and 2) that offsite emergencyorganizations are readily available to respond to the situation. Prompt notification is madeto state officials and follow-up information is provided as needed to offsite emergencyorganizations. Unassigned personnel are evacuated from the site. In an Alert, the stepslisted in the Notification of Unusual Event Response section (except for the terminationprocess) and the following are performed:1. The Alert emergency notification and response, as shown in Figure 9.1 anddescribed in Table 9.1 are implemented;2. The Technical Support Center, Operations Support Center, the EmergencyOperations Facility/Recovery Center, and the Joint Information Center areactivated by personnel as shown in Table 9.1;-3. If sufficient personnel are not available onsite, off-duty personnel are called inas specified in the emergency implementing procedures;4. The Emergency Plant Manager reports to the Technical Support Center anddirects in-plant emergency operations;5. The E©F-ManO.FeEmercency Director establishes operations in the EOF/RC;Emergency PlanRevision 54PENDINGPage 83 of 125Entergy Vermont Yankee 9.2.4. General Emergency ResponseAll Emergency Centers are activated and all available resources are called upon in theevent of a General Emergency. The plant promptly notifies offsite authorities and initiatesall emergency response organization capabilities.Offsite authorities fully activate their emergency response and implement appropriateprotective measures based on meteorological information, actual or projected radiologicaldose conditions and/or conditions. The Emergency Director and the entire emergencyresponse organization assemble plant status parameters and continually advise offsiteauthorities of the type of public protective action most appropriate to the situation based onplant conditions and offsite dose projections. This includes whether to shelter or evacuatethe affected towns within the plume exposure emergency planning zone. In a GeneralEmergency, the steps listed in the Site Area Emergency Response section and thefollowing are performed:1. The Emergency Director may request that the --Manager mobilize otherpersonnel be mobilized in support of Vermont Yankee through activation ofthe Corporate Emergency Center;2. Other nuclear industry resources are alerted and requested to renderappropriate assistance;3. The full resources of the National Response Framework are activated; and4. Dissemination of information and instructions associated with protectiveactions to the public is the principal focus of all response organizations. Theplant fully participates in these efforts by providing detailed emergencycondition information.9.3. Emergency De-Escalation and Termination CriteriaClassification of an accident condition requires that the plant operation staff recognize thatpre-established EALs associated with an emergency condition, as defined in Appendix A,have been reached or exceeded.De-escalation criteria require (1) an extensive review of plant parameters and/or offsiteradiological conditions in conjunction with the pre-established EALs; (2) review of plant andoffsite conditions with offsite authorities; and (3) concurrence by offsite authorities as to theappropriate time frame required to implement de-escalation.Emergency PlanRevision 54PENDINGPage 85 of 125Entergy Vermont Yankee BVY 14-054Docket 50-271Attachment 3Vermont Yankee Nuclear Power StationUpdated Tabular Summary of Proposed Changes to SEP Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable of Contents -- Updated page numbers as necessary Editorial revision to reflect changesdescribed below.Table of Contents -List of Figures Figure 8.1 Normal On-Shift Figure 8.1 Defueled On-Shift VY will no longer be an operatingEmergency Organization Emergency Organization nuclear power plant. The titlechange reflects the permanentlydefueled organizational structure.Table of Contents -List of Figures Figure 8.2 Vermont Yankee Figure 8.2 Vermont Yankee VY will no longer be an operatingEmergency Management Organization Defueled Emergency Management nuclear power plant. The titleOrganization change reflects the permanentlydefueled organizational structure.Table of Contents -List of Figures Figure 8.3 Technical Support Figure 8.3 Defueled Technical VY will no longer be an operatingCenter Emergency Organization Support Center Emergency nuclear power plant. The titleOrganization change reflects the permanentlydefueled organizational structure.Table of Contents -List of Figures Figure 8.4 Operations Support (Deleted) ERO Staffing changes result in oneCenter Emergency Organization remaining OSC position (OSCManager) illustrated on the figure.A figure is no longer necessary todescribe the OSC organization.Table of Contents -List of Figures Figure 8.5 Emergency Figure 8.5 Defueled Emergency VY will no longer be an operatingOperations Facility Organization Operations Facility Organization nuclear power plant. The titlechange reflects the permanentlydefueled organizational structure.Table of Contents -List of Figures Figure 8.7 Joint Information Figure 8.7 Defueled Joint VY will no longer be an operatingCenter Organization Information Center Organization nuclear power plant. The titlechange reflects the permanentlydefueled organizational structure.Section 4.1 Vermont Yankee Nuclear Power Station Vermont Yankee Nuclear Power Station VY will no longer be an operatingis located on the west bank of the is located on the west bank of the nuclear power plant. The SiteConnecticut River immediately Connecticut River immediately Description has been revised toupstream of the Vernon Hydrostation, upstream of the Vernon Hydrostation, indicate the permanently shutdownin the town of Vernon, Vermont. The in the town of Vernon, Vermont. The1 of 21 Emergency Plan Section Before (Rev. 54) After [ Reason for ChangeVermont Yankee Nuclear Power Stationis a boiling water reactor having athermal rated power of 1912 MWt.The station, shown in Figure 4.1, islocated on about 125 acres inWindham County, and is owned byEntergy, with the exception of a narrowstrip of land between the ConnecticutRiver and the Vermont Yankee propertyfor which it has perpetual rights andeasements from the owner, NewEngland Power Company.Vermont Yankee Nuclear Power Stationceased power operations and ispermanently defueled in accordancewith 10 CFR 50.82(a)(1)(i) and (ii). Thestation, shown in Figure 4.1, is locatedon about 125 acres in WindhamCounty, and is owned by Entergy, withthe exception of a narrow strip of landbetween the Connecticut River and theVermont Yankee property for which ithas perpetual rights and easementsfrom the owner, New England PowerCompany.On September 23, 2013, ENOsubmitted a notification of permanentcessation of power operations pursuantto 10 CFR 50.82(a)(1)(i), stating thatENO has decided to permanently ceasepower operation of Vermont Yankee inthe fourth quarter of 2014. ENO hassubmitted written certification to theNRC, in accordance with 10 CFR50.82(a)(1) that meets therequirements of 10 CFR 50.4(b)(9)certifying that fuel has beenpermanently removed from the reactorvessel. Upon docketing of thesecertifications, the 10 CFR Part 50license for VY no longer authorizesoperation of the reactor oremplacement or retention of fuel intothe reactor vessel, as specified in 10CFR 50.82(a)(2).With irradiated fuel being stored in theSpent Fuel Pool and the ISFSl, theand defueled condition.2 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changereactor, reactor coolant system andsecondary system are no longer inoperation and have no function relatedto the storage of the irradiated fuel.Therefore, the postulated accidentsinvolving failure or malfunction of thereactor and reactor coolant system orsecondary system are no longerapplicable.Section 4.2 -2*d Paragraph The nearest house is 1,300 feet from The nearest house is 1,300 feet from Editorial. The Hinsdale Raceway nothe Reactor Building and is one of the Reactor Building and is one of longer operates and reference isseveral west of the site. The Vernon several west of the site. The Vernon removed from the Emergency Plan.Elementary School (approximate Elementary School (approximateenrollment of 250 pupils) is about enrollment of 250 pupils) is about1,500 feet from the Reactor Building. 1,500 feet from the Reactor Building.The nearest hospital, Brattleboro The nearest hospital, BrattleboroMemorial, is approximately five (5) Memorial, is approximately five (5)miles north-northwest from the site. miles north-northwest from the site.The nearest dairy farm is approximately The nearest dairy farm is approximately1/2-mile northwest of the site. 1/2-mile northwest of the site.Additional dairy farms are located Additional dairy farms are locatedwithin a 5-mile radius of the plant. The within a 5-mile radius of the plant. Alargest sports facility in the vicinity is nursing home is located 2 miles souththe Hinsdale Raceway, located of the plant. These areas have beenapproximately three (3) miles from the noted since they have required specialsite. For racing events, the average planning consideration by offsiteattendance is approximately 4,000. A authorities in the event of a radiologicalnursing home is located 2 miles south emergency at Vermont Yankee.of the plant. These areas have beennoted since they have required specialplanning consideration by offsiteauthorities in the event of aradiological emergency at VermontYankee.3 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeSection 8.1 -2nd ParagraphDuring normal operations, theminimum staff on duty at the plantduring all shifts consists of one (1) ShiftManager, one (1) Control RoomSupervisor, two (2) Control RoomOperators, six (6) Auxiliary Operators,one (1) Shift Technical Advisor, one (1)Radiation Protection Technician, one(1) Chemistry Technician and securitypersonnel as indicated in Figure 8.1.The responsibility for determining thestatus of the plant in an emergency isassigned to the Shift Manager or, in hisabsence from the Control Room, to theControl Room Supervisor who has theauthority and responsibility toimmediately initiate any emergencyactions, including emergencyclassification and notification.Additional personnel are available onan on-call basis to respond to plantemergencies. Corrective action andrepair, as outlined in Table 8.4, isperformed by Operations staff on-shiftuntil supplemented by additional EROstaff.The minimum staff on duty at the plantduring all shifts consists of one (1) ShiftManager, one (1) Control RoomSupervisor (CRS)/Certified Fuel Handler(CFH), three (3) Auxiliary Operators(AO)/Control Room Operators(CRO)/Non-Certified Operators (NCO),one (1) Radiation Protection Technicianand security personnel as indicated inFigure 8.1. The responsibility fordetermining the status of the plant inan emergency is assigned to the ShiftManager or, in his absence from theControl Room, to the Control RoomSupervisor who has the authority andresponsibility to immediately initiateany emergency actions, includingemergency classification andnotification. Additional personnel areavailable on an on-call basis to respondto plant emergencies. Corrective actionand repair, as outlined in Table 8.4, isperformed by Operations staff on-shiftuntil supplemented by additional EROstaff.VY will no longer be an operatingnuclear power plant. The followingon-shift positions will beeliminated:* Shift Technical Advisor (STA)" Two (2) Control RoomOperators* Three (3) Auxiliary Operators* Chemistry TechnicianFollowing permanent cessation ofoperations and removal of fuelfrom the reactor vessel, Operationson-shift personnel will consist ofone (1) Shift Manager (SM), one (1)Control Room Supervisor(CRS)/Certified Fuel Handler (CFH)and three (3) Auxiliary Operators(AOs)/Control Room Operators(CROs)/Non-Certified Operators(NCOs). Title changes for the CRS toCFH and the AO and CRO to NCOare dependent upon NRC approvalof proposed changes to the VYTechnical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.These staffing levels have beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanently4 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changedefueled condition.Section 8.2.2 -1st Paragraph, Item 5. Develop guidance for plant shift 5. Develop guidance for plant shift VY will no longer be an operating5 operations concerning plant protection operations concerning plant protection; nuclear power plant andof the reactor core; emplacement or retention of fuelinto the reactor vessel will nolonger be authorized. Therefore,the need for the Emergency PlantManager's responsibilities toinclude protection of the reactorcore is no longer applicable.Section 8.2.2 -2nd Paragraph A qualified manager assumes the role A qualified manager assumes the role VY will no longer be an operatingof Emergency Plant Manager under all of Emergency Plant Manager under all nuclear power plant andemergency conditions. To assist the emergency conditions. To assist the emplacement or retention of fuelEmergency Plant Manager, the TSC is Emergency Plant Manager, the TSC is into the reactor vessel will nostaffed by representatives from the staffed by representatives from the longer be authorized. Therefore,following departments as depicted in following departments as depicted in the need to maintain a ReactorFigure 8.3: Figure 8.3: Engineer in the TSC is no longerapplicable.* Operations 0 Operations* Maintenance 0 Maintenance* Reactor Engineering

• Engineering* Engineering 0 Chemistry* Chemistry (in the OSC) 0 Radiation Protection* Radiation Protection 0 Security (stationed at the off* Security (stationed at the off site command post)site command post)Section 8.2.4 EOF Manager Deleted entire section The EOF Manager position will notexist in the Permanently DefueledERO. Duties and responsibilities willbe transferred to remainingpositions within the EOF.5 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 8.3, Page 2 of 3 Each State Health representative at the Each State Health representative at the The EOF Manager position will notEOF/RC will request monitoring EOF/RC will request monitoring exist in the Permanently Defueledupdates from the EOF Manager. updates from the Lead Offsite Liaison. ERO. Duties and responsibilities willbe transferred to remainingpositions within the EOF.Table 8.3, Page 3 of 3 The Public Information Liaison at the The Technical Advisor at the EOF/RC The position of Public InformationEOF/RC relays accident status reports relays accident status reports to the Liaison will not exist in theto the Joint Information Center. Joint Information Center. Permanently Defueled EmergencyResponse Organization (ERO).Duties and responsibilities will betransferred to the TechnicalAdvisor position.Table 8.4 -Page 1 of 2, Functional ,' shift I Shift fl) I on VY On Sift VY will no longer be an operatingArea -Plant Operations & CRS i1. On Shift CRSCerifiedFuel Handler (CFH.(1) I On Sh,,t nuclear power plant. The following'RO i2i On Sh1f0 i AO1CRO.NCO' "3 OS os nwAssessment of Operational Aspects AO!6l O on-shift positions will beSTA (1I On Shift eliminated:* STA" Two (2) Control RoomOperators* Three (3) Auxiliary Operators" Chemistry TechnicianFollowing permanent cessation ofoperations and removal of fuelfrom the reactor vessel, Operationson-shift personnel will consist ofthe SM, one (1) CRS/ CFH and three(3) AOs/CROs/NCOs. Title changesfor the CRS to CFH and AO and CROto NCO are dependent upon NRCapproval of proposed changes tothe VY Technical Specifications thatreplace references to licensed andnon-licensed operators with6 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changereferences to CFHs and NCOs.These staffing levels have beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanentlydefueled condition.STA oversight and technicalknowledge in this functional areawill be transferred to the ShiftManager and/or the CRS/CFH. Thistransfer of duties has beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents previouslysubmitted to the NRC.Table 8.4 -Page 1 of 2; Functional SlAiAo on ShiOt CR;CFH VY will no longer be an operatingArea -STAgOflsiie Popj iCtminJEHS 30 rain oiffsi:eCommiEt.SCommnnh 3Onuiin nuclear power plant. The STANotification/Communication; i e miQi offsi comm;EttS Comm(2r Lo.m position will be eliminated.Major Tasks -Notify Licensee, ,.Following permanent cessation ofState, local and federal personnel & operations, the Chemistrymaintain communication Technician Position will not beresponsible for performingnotification/communications tasks.STA assignments in this functionalarea will be transferred to aCRS/CFH. This transfer of dutieshas been evaluated in the VYanalysis of proposed post-shutdown on-shift staffing inconjunction with the postulated7 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changeaccidents that will be applicable inthe permanently defueledcondition.Title change for the CRS to CFH isdependent upon NRC approval ofproposed changes to the VYTechnical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.Table 8.4 -Page I of 2; Functional EOF Emrgency D,,eo, i 60 m EOF Emergetc Director il) 60 sn VY will no longer be an operatingArea -Radiological Accident shift O Sf- Shft .CRSCFH On Shift nuclear power plant. The STA andAssessment and Support of R Staff W 30 on-shift Chemistry Tech positionsOperational Accident Assessment; will be eliminated.Major Tasks -Offsite Dose STA assignments in this functionalAssessment area will be transferred to the ShiftManager and/or the Control RoomSupervisor. This transfer of dutiesand removal of the on-shiftChemistry Tech position have beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanentlydefueled condition.Title changes for the CRS to CFH isdependent upon NRC approval ofproposed changes to the VYTechnical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.8 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 8.4 -Page 1 of 2; Functional : .......... ............... ...- ........ ..._;" This change does not represent aShit RP tech~ (I i hift ------- -- --6n_ .30mm This chonge doesmnot1represent aArea -Radiological Accident Fieldmonilonng eamsn(1 30 min. !FeLrimontnntams () --mln 4 change to thenumberofon-shiftAssessment and Support of Feldnonitormnteams1) 60 RP Technicians. The number of on-Operational Accident Assessment; shift RP Technicians remains oneMaior Tasks -Onsite (out of plant) (1). The change is intended toclarify VY's RP Technician dutiesduring an emergency, consistentwith Table B-1 of NUREG-0654.Table B-1 of NUREG-0654 does notidentify an on-shift positionresponsible for "onsite (out ofplant)" surveys. During the initialstages of an emergency, the on-shift RP Technician will be assignedto the most critical tasks during theemergency response. VY maintainsthe capability to augment on-shiftstaff with field monitoring teams toperform this task within 30 minutesof notification of an emergencydeclaration.Table 8.4- Page 1 of 2; Functional Shift Chem Tech it! On ShIft I emsar(i VY will no longer be an operatingArea -Radiological Accident Chem st1 60 I nuclear power plant. The on-shiftAssessment and Support of Chemistry Tech position will beOperational Accident Assessment; eliminated.Major Tasks -Removal of the on-shift ChemistryChemistry/Radiochemistry Tech position has been evaluatedin the VY analysis of proposed post-shutdown on-shift staffing inconjunction with the postulatedaccidents that will be applicable inthe permanently defueledcondition.9 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 8.4- Page 1 of 2; Functional I To Shift P ......... Po ,ni~o .-n.e.c.d .. e '.. d -..e ..n ..... .VY will no longer be an operatingArea -Plant System Engineering; TSC RE 30 mmi P eso' led flCo.dlroa " nO nuclear power plant. The STAMajor Tasks -Shift Technical position will be eliminated.Advisor and Core Thermal STA oversight and technicalHydraulics knowledge in this functional areawill be transferred to the ShiftManager and/or the CRS/CFH. Thistransfer of duties has beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanentlydefueled condition.Additionally, the need to maintaina Reactor Engineer in the TSC is nolonger applicable.Table 8.4 -Page 1 of 2; Functional The Defueled Organization containsShift AO il'i CiSt Shift ACGRO.NCO(1") onShiftArea -Repair & Corrective Actions; three (3) AOs/CROs/NCOs on-shift.Major Tasks -Mechanical This on-shift complement has beenMaintenance evaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanentlydefueled condition.Title change for the AO and CRO toNCO is dependent upon NRCapproval of proposed changes tothe VY Technical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.10 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 8.4 -Page I of 2; Functional The CRO position is eliminated inArea -Repair & Corrective Actions; -OCRO 60 mi AC',RONCO O m, the post-shutdown condition. TheMajor Tasks -Rad Waste Operator Defueled Organization consists ofthree (3) AOs/CROs/NCOs on-shift.This on-shift complement has beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanentlydefueled condition.Title change for the AO and CRO toNCO is dependent upon NRCapproval of proposed changes tothe VY Technical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.Table 8.4- Page 1 of 2; Functional n.i. O o o -- The Defueled Organization consistsArea -Repair & Corrective Actions; ,,in.enw.ce fl 30 ... Maintenance (1) 30 min of three (3) AOs/CROs/NCOs on-Major Tasks -Electrical .Annnnce 60mm. Maintenance ..) I. 6.m shift. This on-shift complement hasMaintenance/Instrumentation & been evaluated in the VY analysisControl Technician of proposed post-shutdown on-shift staffing in conjunction withthe postulated accidents that willbe applicable in the permanentlydefueled condition.Title change for the AO and CRO toNCO is dependent upon NRCapproval of proposed changes tothe VY Technical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.11 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 8.4 -Page 2 of 2; Functional shift AO i2.. : On Shift Shift AO'CRO'NC0,2"): On Shf The Defueled Organization consistsArea -Protective Actions (In Plant); RP iý2 30 RP 2) 30 of three (3) AOs/CROs/NCOs on-RP 2) 6o min, (3 i2 60mC onMajor Tasks -Radiation Protection, shift. This on-shift complement hasaccess control, HP, coverage for been evaluated in the VY analysisrepair, corrective actions, search & of proposed post-shutdown on-rescue, first aid & firefighting, shift staffing in conjunction withpersonnel monitoring, dosimetry the postulated accidents that willbe applicable in the permanentlydefueled condition.Title change for the AO and CRO toNCO is dependent upon NRCapproval of proposed changes tothe VY Technical Specifications thatreplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.Table 8.4, Note

• May be performed by engineering aide Title Change is dependent on NRC VY will no longer be an operatingto Shift Manager (STA for ENVY) approval of revised Technical nuclear power plant. The STASpecifications (BVY 13-096, dated position will be eliminated. STA10/31/13). CFHs will supervise fuel oversight and technical knowledgehandling operations in the permanently will be transferred to the Shiftdefueled condition. The CRS and SM Manager and/or the CRS/CFH. Thiswill be qualified as CFHs. However, the transfer of duties has beenSM requires additional qualification evaluated in the VY analysis ofbeyond the CFH training. Therefore, proposed post-shutdown on-shiftany reference to the CFH position staffing in conjunction with thethroughout this Plan is considered to be postulated accidents that will beequivalent to the CRS position. Non- applicable in the permanently,Certified Operators will perform duties defueled condition.typically associated with those Title changes for the CRS to CFHperformed by Auxiliary Operators and and AO and CR0 to NCO areControl Room Operators, such as dependent upon NRC approval ofmanipulation and monitoring of plant proposed changes to the VYequipment. Technical Specifications that12 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changereplace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.Table 8.4, Note 1 AP 0894 specifies minimum shift AP 0894 specifies minimum shift The Defueled on-shift staffing hasstaffing requirements. FB requires 5 staffing requirements. FB requires 5 been evaluated in the VY analysispersons per TRM and the Vermont persons per TRM and the Vermont of proposed post-shutdown on-Yankee Nuclear Power Station On-Shift Yankee Nuclear Power Station Analysis shift staffing in conjunction withStaffing Analysis. The staffing analysis of Proposed Post-Shutdown On-Shift the postulated accidents that willis maintained as a controlled document Staffing. The staffing analysis was be applicable in the permanentlyand is effective 30 days after OSRC evaluated to reflect VY's permanently defueled condition.approval. STA and Chemistry Tech shutdown and defueled conditions,must be available within 10 minutes to including the on-shift staff compositionthe Control Room. VY letter to N RC and revised accident analyses.dated 4/14/1981 (FVY 81-65)establishing position. VY letter to NRC6/22/1982 (FVY 82-75) Supplement-NUREG 0737 Item III.A.1.2 on trainingof on-shift staff to support VY positionfor staffing. VY letter to NRC4/14/1981 (FVY 81-65) TMI Action PlanItem III.A.1.2, goal for augmentation ofstaff. VY letter to NRC 6/15/82 (FVY82-70) Results of Augmentation drills tosupport use of goals. Titles of ENVYERO positions are shown.Table 8.4, Note 2 All AOs use digital dosimeters with All AOs/CROs/NCOs use digital Title change for the AOs and CROsfeatures for dose rate and total dose dosimeters with features for dose rate to NCO is dependent upon NRCmonitoring. AOs are trained to self- and total dose monitoring, approval of proposed changes tomonitor in an emergency. AOs/CROs/NCOs are trained to self- the VY Technical Specifications thatmonitor in an emergency. replace references to licensed andnon-licensed operators withreferences to CFHs and NCOs.Table 8.4, Note 3 ENVY has designated pager holders ENVY has designated ERO members The Defueled Organization willwho staff positions required to meet who staff positions required to meet consist of fewer than 4 teams13 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changeminimum staffing to activate TSC, OSC minimum staffing to activate the TSC, rotating ERO duty.and EOF (see E Plan Figures 8.3 through OSC and EOF. The minimum staff Additional changes to this note are8.5). There are a minimum of 4 positions required to activate the TSCpersons per position (4 teams who and EOF are shown in E Plan Figures 8.3 editrial to r ovrers trotate duty). However, all persons on and 8.5. The OSC Manager is the onlyteams are expected to respond. In position required to activate and staffaddition, all other ERO personnel not the OSC. All ERO personnel areon pagers are notified by the expected to respond when notified byemergency call-in notification system the emergency call-in notificationand are expected to respond. system.Table 8.4, Note 4 The on-shift Shift Manager, CRS, STA, The on-shift Shift Manager and CRS VY will no longer be an operatingand Chem Tech have the capability to have the capability to do initial dose nuclear power plant. The STA anddo initial dose assessment and PAR. assessment and PAR. The TSC and EOF on-shift Chemistry TechnicianThe TSC and EOF radiation assessment radiation assessment staff relieves positions will be eliminated.staff relieves them of this function. them of this function.Figure 8.1 Normal On-Shift Emergency Replaced figure with "Defueled On- VY will no longer be an operatingOrganization Shift Emergency Organization" figure. nuclear power plant. The followingon-shift positions will beDeleted the following positions: eliminated:* Shift Technical Advisor* STA* Chem TechC Two (2) Control Room* Control Room Operators OperatorsReplaced "Auxiliary Operators" with 0 Three (3) Auxiliary Operators"AOs/CROs/NCOs" 0 Chemistry TechnicianFollowing permanent cessation ofoperations and removal of fuel *from the reactor vessel, Operationson-shift personnel will consist ofthe (SM, one (1) CRS/ CFH andthree (3) AOs/CROs/NCOs. Titlechanges for the CRS to CFH and AOand CRO to NCO are dependentupon NRC approval of proposed14 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changechanges to the VY TechnicalSpecifications that replacereferences to licensed and non-licensed operators with referencesto CFHs and NCOs.These staffing levels have beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents that will beapplicable in the permanentlydefueled condition.STA oversight and technicalknowledge in this functional areawill be transferred to the ShiftManager and/or the CRS/CFH. Thistransfer of duties has beenevaluated in the VY analysis ofproposed post-shutdown on-shiftstaffing in conjunction with thepostulated accidents previouslysubmitted to the NRC.Figure 8.2 VY Emergency Management Replaced figure with "VY Defueled The positions of EOF Manager andOrganization Emergency Management Organization" TSC Manager will not exist in thePermanently Defueled ERO. DutiesDeleted the following positions: adrsosblte ilband responsibilities will be" EOF Manager transferred to remaining positions" TSC Manager within each Emergency ResponseFacility.Figure 8.3 Technical Support Center Emergency Replaced figure with "Defueled The TSC positions identified forOrganization Technical Support Center Emergency deletion will not exist in theOrganization" Permanently Defueled ERO. DutiesDeleted the following positions: and responsibilities will be15 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Change" TSC Manager transferred to remaining positions" TSC Communicator within the TSC." Mechanical Engineer* Reactor Engineer* Electrical /I&C Engineers* IT SpecialistFigure 8.4 Operations Support Center Emergency Deleted figure ERO Staffing changes result in oneOrganization remaining OSC position (OSCManager) -A figure is no longernecessary to describe the OSCorganization.Figure 8.5 Emergency Operations Facility Replaced figure with "Defueled The EOF positions identified forOrganization Emergency Operations Facility deletion will not exist in theOrganization" Permanently Defueled ERO. DutiesDeleted the following positions: and responsibilities will betransferred to remaining positions* EOF Manager within the EOF.* EOF Communicator" Public Information Liaison* EOF Log Keeper" IT SpecialistFigure 8.7 Joint Information Center Organization Replaced figure with "Defueled Joint The JIC positions identified forInformation Center Organization" deletion will not exist in theDeleted the following positions: Permanently Defueled ERO. Dutiesand responsibilities will be" Information Coordinator transferred to remaining positions* Technical Assistant within the JIC.* Credentialing* Press Release Writer" Logistics Coordinator" Inquiry Response Coordinator* Media Monitoring* JIC Log Keeper16 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Change0 Inquiry RespondersSection 9.2.1 -2nd Paragraph 3. The Shift Technical Advisor reports Deleted VY will no longer be an operatingto the Control Room and provides nuclear power plant. The STAtechnical support as necessary; position will be eliminated.STA assignments in this functionalarea will be transferred to aCRS/CFH. This transfer of duties hasbeen evaluated in the VY analysisof proposed post-shutdown on-shift staffing in conjunction withthe postulated accidents that willbe applicable in the permanentlydefueled condition.Section 9.2.2 5. The EOF Manager establishes 5. The Emergency Director The EOF Manager position will notoperations in the EOF/RC; establishes operations in the exist in the Permanently DefueledEOF/RC: ERO. Duties and responsibilities willbe transferred to remainingpositions within the EOF.Section 9.2.4 -2nd Paragraph 1. The Emergency Director may 1. The Emergency Director may The EOF Manager position will notrequest that the EOF Manager request that other personnel be exist in the Permanently Defueledmobilize other personnel in mobilized in support of Vermont ERO. Duties and responsibilities willsupport of Vermont Yankee Yankee through activation of the be transferred to remainingthrough activation of the Corporate Emergency Center. positions within the EOF.Corporate Emergency Center.Section 9.3 -3 Paragraph De-escalation from a Notification of De-escalation from a Notification of VY will no longer be an operatingUnusual Event to a recovery phase Unusual Event to a recovery phase nuclear power plant andrequires satisfying the following requires satisfying the following emplacement or retention of fuelcriteria: criteria: into the reactor vessel will nolonger be authorized. Therefore,1. Criticality controls are in effect; 1. Criticality controls are in effect; the ne a u ate core cooi,the need for adequate core cooling,2. The core is being adequately 2. The fission product release has control over containment pressurecooled; been controlled; and temperature and control ofreactor coolant system pressure is17 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Change3. The fission product release has 3. An adequate heat transfer path to not necessary.been controlled; an ultimate heat sink has beenestablished;4. Control has been established overcontainment pressure and 4. Notification of Unusual Eventtemperature; conditions have been reviewed,5. An adequate heat transfer path to are under control, and are notan ultimate heat sink has been expected to deteriorate further.established;6. Reactor coolant system pressure isunder control; and/or7. Notification of Unusual Eventconditions have been reviewed,are under control, and are notexpected to deteriorate further.Table 9.1, Technical Support Emergency Plant Manager Emergency Plant Manager The TSC positions identified forCenter; Alert or Site Area deletion will not exist in theEmergency or General Emergency (Electrical/Mechanical/n&C) Permanently Defueled ERO. DutiesColumn Maintenance Coordinator and responsibilities will be(Electrical/Mechanical/l&C) Radiological Coordinator transferred to remaining positionsRadiological Coordinator Engineering Coordinator(Project, within the TSC.Reactor Engineer System, Design)Engineering Coordinator(Project, Operations CoordinatorSystem, Design)Operations CoordinatorEngineering Support GroupTable 9.1, Operations Support OSC Manager OSC Manager VY will no longer be an operatingCenter; Alert or Site Area Radiation Protection Staff Radiation Protection Staff nuclear power plant. Use of theEmergency or General Emergency term "licensed" is no longerChemistry Staff Chemistry Staff appropriate.The OSC positions identified for18 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeSpare Licensed Operators Spare AOs/CROs/NCOs deletion will not exist in theSpare Auxiliary Operators Control Instrument Specialists Permanently Defueled ERO. Dutiesand responsibilities will beControl Instrument Specialists Plant Mechanics transferred to remaining positionswithin the OSC.Plant MechanicsTable 9.1, Emergency Operations Emergency Director Emergency Director The EOF positions identified forFacility/Recovery Center; Alert or Offsite Communicator Offsite Communicator deletion will not exist in theSite Area Emergency or General Permanently Defueled ERO. DutiesEmergency Column Technical Advisor Technical Advisor and responsibilities will betransferred to remaining positionsEOF Manager Administration and Logistics within the EOF.Administration and LogisticsCoriarCoordinator Radiological Assessment CoordinatorRadiological Assessment Coordinator *Site/Offsite Monitoring TeamsPersonnel & Equipment Monitor*Site/Offsite Monitoring TeamsPublic Information LiaisonTable 9.1, Joint Information Center; Company Spokesperson Company Spokesperson The JIC positions identified forAlert or Site Area Emergency or VY Public Information Staff deletion will not exist in theGeneral Emergency Permanently Defueled ERO. DutiesNuclear Public Information and responsibilities will beRepresentatives transferred to remaining positionsJoint Information Center Staff within the JIC.Section 10.2 -Ist Paragraph In the event a General Emergency has In the event a General Emergency has VY will no longer be an operatingbeen declared, Vermont Yankee been declared, Vermont Yankee nuclear power plant andimmediately recommends protective immediately recommends protective emplacement or retention of fuelactions to state authorities based on actions to state authorities based on into the reactor vessel will noplant conditions which include the plant conditions. At a minimum, the longer be authorized. Therefore,status of core and containment Shift Manager or Emergency Director, the need to communicate theconditions. At a minimum, the Shift who is in charge of the emergency status of the core and containmentManager or Emergency Director, who is response activities, recommends that conditions is not necessary.19 of 21 Emergency Plan Section Before (Rev. 54) After Reason for Changein charge of the emergency response the general public be advised to seekactivities, recommends that the general shelter for the towns of Hinsdale, Newpublic be advised to seek shelter for Hampshire and Vernon, Vermont; andthe towns of Hinsdale, New Hampshire the towns located five miles downwindand Vernon, Vermont; and the towns in the affected sectors.located five miles downwind in theaffected sectors.Section 10.2 -2nd Paragraph If plant conditions indicate a severe If plant conditions indicate a severe VY will no longer be an operatingreactor accident exists involving actual accident exists, Vermont Yankee nuclear power plant andor projected substantial core damage, recommends to the appropriate state emplacement or retention of fuelVermont Yankee recommends to the officials evacuation of the towns of into the reactor vessel will noappropriate state officials evacuation of Hinsdale, New Hampshire and Vernon, longer be authorized. Therefore, anthe towns of Hinsdale, New Hampshire Vermont; and all towns located five accident involving the reactor theand Vernon, Vermont; and all towns miles downwind in the affected sectors. potential for actual or projectedlocated five miles downwind in the substantial core damage no longeraffected sectors. exists.Section 10.3 -2nd Paragraph Table 10.2 specifies the guidelines on Table 10.2 specifies the guidelines on VY will no longer be an operatingemergency dose limits for personnel emergency dose limits for personnel nuclear power plant. The on-shiftproviding emergency response duties providing emergency response duties Chemistry Technician positions willwhich is consistent with the which is consistent with the be eliminated.Environmental Protection Agency Environmental Protection AgencyEmergency Worker Dose Limit Guides Emergency Worker Dose Limit Guides(EPA 400-R-92-001). The Shift Manager (EPA 400-R-92-001). The Shift Managerinitially has the responsibility to initially has the responsibility toauthorize emergency dose authorize emergency dosecommitments until relieved by the commitments until relieved by theEmergency Plant Manager. This Emergency Plant Manager. Thisauthorization is coordinated with the authorization is coordinated with theassistance of the Radiological assistance of the RadiologicalCoordinator or Shift Chemistry and Coordinator and Radiation ProtectionRadiation Protection Technicians as Technicians as needed. Exposure toneeded. Exposure to individuals individuals providing emergencyproviding emergency functions will be functions will be consistent with theconsistent with the limits specified in limits specified in Table 10.2 with every20 of 21 Emergency Plan Section Before (Rev. 54) After Reason for ChangeTable 10.2 with every attempt made to attempt made to keep exposureskeep exposures ALARA. ALARA.Section 11.3 -4 Paragraph The Public Information Liaison and The Technical Advisor and required The Technical Advisor will assumerequired staff report to the EOF/RC for staff report to the EOF/RC for this duty in the permanentlycoordinating the accident information coordinating the accident information defueled condition.between the plant and the Joint between the plant and the JointInformation Center. Information Center.21 of 21